IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG
vs.
SCOTT ROTHSTEIN individually, J. , individually,
Defendant/Counter-Plaintiff. CO S
#### /Mk NOTICE OF E-FILING EXHIBITS
Plaintiff/Counter-Defendant Jeffrey Epsteiik\_ d through his undersigned counsel and pursuant to Rule 2.516 of the Florida Rules of Judicial Administration, hereby files his exhibits to Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment on Defendant/Counter-Plaintiff Fourth Amended Counterclaim T acd ortSupporting Memorandum of Law ("Motion"), previously filed and accepted b the P Beach County, Florida Civil Division Filing # 5846906. The files accompanyin this Notice of Filing Exhibits were previously filed on September 26, 2013 and again on October 2, 2013, but moved to Pending Queue due to procedural issues. filing is an attempt to correct those procedural issues. The attachment hereto cont;4tre the exhibits to the above referenced Motion, which is not being re-filed contemporaneously herewith. However, the exhibits arc being divided based upon the filing requirements of the rules of e-filing; each new exhibit begins when so marked on the is so marked on the bottom of the first page of said exhibit.
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, via electronic service (through the e-file portal), to all parties on the attached service list, this October 3, 2013.
> /s/ Toni Haddad Cole Tonja Haddad Colem Florida Bar No.: 176 Tonja Haddad, P 5315 SE 7th S Suite 301 Fort Lauderd 954.467.1223 954.3373716 (facsimile) o s for Epstein
### SERVICE LIST
CASE NO. 502009CA040800XXXXMBAG
Jack Scarola, Esq. jsx@searcylaw.com; mcp@searcylaw.com Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. ,1O4' West Palm Beach, FL 33409
Jack Goldberger, Esq. jgoldbergcr@agwpa.com; smahoney@agwpa.com Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401
iS 5)
Marc Nurik, Esq. East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301
J. Esq. abr athtojusticc.com Jaffe Weissing Ed 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florid 39301
Fred Haddad, Dee@FredHaddadLaw.com 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301
W. Chester =, Jr., Esq. weblavviiiaol.conv wcbcg@aol.com W. Chester Jr., P.A. One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401
(con't)
? S"
Tonja Haddad Coleman, Esquire\
Tonja@tonjahaddad.com; efiling@tonjahaddad.com\
Law Offices of Tonja Haddad, P.A.\
315 SE 7th Street, Suite 301\
Fort Lauderdale, FL 33301\
Attorneys for Jeffrey Epstein
NOT A CERTIFIED COPY
| Disposition Amount: | | |
| -------------------------- | ------------------------------------- | --- |
| Docket Text: | none. | |
| 96 | ANAD - ANSWER & AFFIRMATIVE DEFENSES | |
| Filing Date: | 19-AUG-2009 | |
| Filing Party: | EPSTEIN, JEFFREY | |
| Disposition Amount: | | |
| Docket Text: | TO 2ND AMENDED COMPLAINT | |
| 97 | NOTD - NOTICE OF TAKING DEPOSITION | |
| Filing Date: | 19-AUG-2009 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | OF EW C/O BRAD [REDACTED] ESQ. | |
| 98 | NOTD - NOTICE OF TAKING DEPOSITION | |
| Filing Date: | 19-AUG-2009 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | OF LM C/O BRAD EDWARDS ESQ. | |
| 99 | NPNP - NOTICE OF PRODUCTION NON PARTY | |
| Filing Date: | 20-AUG-2009 | |
| Filing Party: | [REDACTED], BRAD | |
| Disposition Amount: | | |
| Docket Text: | none. | |
| 100 | NNAC - NOTICE -NAME/ADDRESS CHANGE | |
| Filing Date: | 20-AUG-2009 | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | |
| Disposition Amount: | | |
| Docket Text: | none. | |
| 101 | ORD - ORDER | |
Tiling Date: :24-AUG-2009 I
Filing Party: i
----J
Disposition Amount:
Docket Text: , i ON MOT FOR SPECIAL SET HEARING, DENIED. D HAFELE.
104 ORD - ORDER
\[riling Date: 24-AUG-2009
i Filing Party: L
Disposition Amount:
Docket Text: rT'S MOTION TO STAY IS HEREBY J THE TRANSCRIPT DTD 8/20/09 GRANTED FORTH IN D HAFELE
105 OBJ - OBJECTION
Filing Date: I 24-AUG-2009
------ Filing Party: EPSTEIN, JEFFREY
)' ipisposition Amount: i
Docket Text: , TO NOTICES OF PRODUCT FOR PROTECTIVE ORDER-M NON-PARTIES AND MOTION \_\_\_\_\_
106 , ORD - ORDER
- - — --",,,,,--- I Filing Date: _ j24-AUG-2009
Filing Party:
. Di. . . sposition Amount:
—ION Docket Text: MOT TO COMPEL COMPLIANCE, VIEW ORDER. D HAFELE. GRANTED AS FOLLOWS
102 I I RNTD - RE-NOTICE OF TAKING DEPOSITION ----
Filing Date: 25-AUG-2009
Filing Party:
• - —7 Disposition Amount:
Docket Text: , lilone.
103 RNTD - RE-NOTICE OF TAKING TI DEPOSITION
Filing Date: - - - — 25-AUG-2009 ".----
I Filin g Pa rty:\_ —
, Disposition Amount:
| 107 | RNTD - RE-NOTICE OF TAKING DEPOSITION | | |
| ----- | --------------------------------------- | --- | --- |
| ----- | --------------------------------------- | -- | -- |
**Filing Date:** 27-AUG-2009
**Filing Party:**
**Disposition Amount:**
**Docket Text:** *none.*
| 108 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| ----- | ------------------------------------ | --- | --- |
| ----- | ------------------------------------ | -- | -- |
**Filing Date:** 27-AUG-2009
**Filing Party:**
**Disposition Amount:**
**Docket Text:** *none.*
| 109 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| ----- | ------------------------------------ | --- | --- |
| ----- | ------------------------------------ | -- | -- |
**Filing Date:** 27-AUG-2009
**Filing Party:**
**Disposition Amount:**
**Docket Text:** *none.*
| 110 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| ----- | ------------------------------------ | --- | --- |
| ----- | ------------------------------------ | -- | -- |
**Filing Date:** 27-AUG-2009
**Filing Party:**
**Disposition Amount:**
**Docket Text:** AMENDED
| 111 | RNTD - RE-NOTICE OF TAKING DEPOSITION | | |
| ----- | --------------------------------------- | --- | --- |
| ----- | --------------------------------------- | -- | -- |
**Filing Date:** 27-AUG-2009
**Filing Party:**
**Disposition Amount:**
**Docket Text:** *none.*
| 112 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| ----- | ------------------------------------ | --- | --- |
| ----- | ------------------------------------ | -- | -- |
Filing Party:
\[nispositiot --- irnount: .
Docket Text: ,-none
113 l ! NOTD - DEPOSITION NOTICE OF TAKING
Filing Date: I27-AUG-2009
Filing Party:
Disposition Amount
Docket Text: none. _ .....1
114 NOS - NOTICE OF SERVICE
— -- 41-- - - -- -- - - -
.1
\[Filing Date: i 01-SEP-2009
Filing Party: M, L i
Disposition Amount: '
Docket Text: -1none. r J
1115 t RESP - RESPONSE TO:
Filing Date: 01-SEP-2009
Filing Party: I _ M, L
Disposition Amount:
Docket Text: I none.
1r r—raiN07bnff sr DEPOSITION i
Filing Date: 10-SEP-2009
Filing Party:
Disposition Arno nt: '
Docket Text: , none
IL17 NOTD - ! DEPOSITION NOTICE OF TAKING i !
Filing Date: 10-SEP-2009
I Filing Party:
Disposition Amount:
Docket Text: none
118 NOTD - NOTICE OF TAKING
# DEPOSITION II
Filing Date: 10-SEP-2009
Filing Party:
Disposition Amount: ,
LDocket Text: ,\[none.
119 I 1 , NCAN - NOTICE OF CANCELLATION
Filing Date: 10-SEP-2009
Filing Party:
Disposition Amount: i
Docket Text: LDEPO
120 ; NOH - NOTICE OF HEARING
Filing Date: 10-SEP-2009
Filing Party:
Disposition Amount
Docket Text: none.
121 i 'PARTY NPNP - NOTICE OF PRODUCTION NON
Filing Date: 11-SEP-2009 i
Filing Party:
Disposition Amount . . \_
!
Docket Text: (none.
122 RESP - RESPONSE TO:
Filing Date: i 11-SEP-2009
Filing Party:
Disposition Amount 1
Docket Text: ' PLTF'S REQUEST FOR PRODUCTION
123 NPNP - PARTY NOTICE OF PRODUCTION NON \_J..
Filing Date: ' -- ).--- 11-SEP-2009
Filing Party:
\[Disposition Amount: ,
Docket Text: tone.
| 125 | t |
| ---------------------------------- | ------------------------------- |
| Filing Date: | 16-SEP-2009 |
| Disposition Amount: | ' |
| Docket Text: | none. |
| , 126 | NOH - NOTICE OF HEARING ll : |
| Disposition Amount: 1 Docket Text: | I |
| 127 | i NOTD - |
| Filing Date: | 17-SEP-2009 |
| Docket Text: | SEE LIST S. |
| "---r 128 | ! RNOT - RE-NOTICE A |
| t Filing Date: | 18-SEP-2009 |
| !Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| , Docket Text: | none. |
| | RE-NOTICE OF TAKING r |
| Filing Date: | 421-SEP-2009 |
| Docket Text: | none. |
| 130 | OBJ - OBJECTION |
| Filing Date: | 21-SEP-2009 |
| Filing Party: | EPSTEIN, JEFFREY |
| Docket Text: | none. |
| 131 | OBJ - OBJECTION ! |
| --------------------- | ------------------------------------ |
| Filing Date: | ,21-SEP-2009 |
| Filing Party: | EPSTEIN, JEFFREY |
| Docket Text: | , |
| | AMENDED — |
| | , ......., |
| 1124 | I NOF - NOTICE OF FILING |
| Filing Date: | 122-SEP-2009 |
| Filing Party: | ----1EPSTEIN, JEFFREY \_\_\_, |
| Docket Text: | EMERGENCY MOT, UP 9/22/09. |
| 132 | MOT - MOTION |
| Filing Date: | 1 23-SEP-2009 4...- |
| Filing Party: | , M, L |
| Docket Text: | IIFOR PROTECTIVE ORDER |
| 133 | ORD - ORDER |
| | i Filing Date: 4. 23-SEP-2009 |
| Disposition Amount: 1 | \_Ae") |
| Docket Text: | \[ON MTN FOR PROTECTIVE ORDER GRANTED |
| 1134 | RNOT - |
| | ---, or - -7- |
| Filing Date: | 24-SEP-2009 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Docket Text: | 1 \_ |
| | none. \_\_\_ -A. |
| 135 | : RESP - RESPONSE TO: |
| Filing Date: | \_124-SEP-2009 |
| Filing Party: | ; |
| Docket Text: | none. — - -- — |
| I 138 | ; NOH - NOTICE OF HEARING |
| 'Filing Date: | "25-SEP-2009 |
| -------------- | -------------------------------- |
| 'Filing Party: | 1 |
| Docket Text: | t9CT 1 2009 |
| , 139 | NCAN - NOTICE OF CANCELLATION 1 |
| (Filing Date: | 28-SEP-2009 |
| Docket Text: | OF DEPO |
| 147 | NOH - NOTICE OF HEARING |
| Filing Date: | 28-SEP-2009 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESL) |
| Docket Text: | none. |
| i FaTE- 1 | NOH - NOTICE OF HEARING |
| Filing Date: | '29-SEP-2009 --I |
| \[Docket Text: | I none. |
| 141 | MOT - MOTION |
| Filing Date: | 29-SEP-2009 |
| Filing Party: | IEPS ?N, JEFFREY |
| Docket Text: | none. |
| 142 | MSJT - MOT/NOT TO SET JURY TRIAL |
| Filing Date: | 01-OCT-2009 |
| Filing Party: | IIM, L i |
| lDocket Text: | ilUP |
| 143 | ! |
| Filing Date: | 02-OCT-2009 J |
Disposition Amount:
Docket Text: j none.
136 i I MOT - MOTION
Filing Date: 06-OCT-2009 \_\_
Filing Party: M, L
Disposition Amount 1
Docket Text: none.
137 I MOT - MOTION I
... .
Filing Date: .\_ .. ;06-OCT-2009
Filing Party: 1M, L,
Disposition Amount:
p 3ocket Text: jnone
144 EMOT - EMERGENCY MOTION r
Fi g I lin Date: I 06-OCT-2009
I - (Filing Party: IM,L
Disposition Amount: I C\\
Docket Text: FOR ENFORCEMENT OF ORDER ANONYMOUSLY THROUGH SEALING GRANTING LEAVE TO OF HER DEPO (UP PROCEED 10-9-09)
145 t MCMP - MOTION TO COMPEL 1 \[
Filing Date: 107-OCT-2009
Filing Party: EPSTEIN, JEFFREY
Disposition Amount: 1
Docket Text: none.
146 , RNTD - DEPOSITION RE-NOTICE OF TAKING
Filing Date: 07-OCT-2009
Filing Party:
Disposition Amount:
Docket Text: 'pone. \_\_\_\_\_\_
s
______________________________________________________________________
148 i NOTD - DEPOSITION NOTICE OF TAKING
.
Filing Date: 109-OCT-2009
| Filing Party: | | | |
| -------------------------- | ------------------------------------- | --- | --- |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 149 | MOT - MOTION | | |
| Filing Date: | 09-OCT-2009 | | |
| Filing Party: | M, L | | |
| Disposition Amount: | | | |
| Docket Text: | TERMINATE DEPO | | |
| 150 | RNTD - RE-NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 13-OCT-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | DAVID HART ROGERS | | |
| 151 | RNTD - RE-NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 13-OCT-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | LARRY VISOSKI | | |
| 152 | NOH - NOTICE OF HEARING | | |
| Filing Date: | 13-OCT-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 153 | MOT - MOTION | | |
| Filing Date: | 13-OCT-2009 | | |
| Filing Party: | EPSTEIN, JEFFREY | | |
| Disposition Amount: | | | |
| Docket Text: | FOR PROTECTIVE ORDER | | |
| 154 | NOF - NOTICE OF FILING | | |
| Filing Date: | 14-OCT-2009 | | |
| Filing Party: | EPSTEIN, JEFFREY |
| --------------------- | --------------------------------- |
| Docket Text: | none. |
| 155 | RESP - RESPONSE TO: |
| Filing Date: | 15-OCT-2009 |
| Filing Party: | M, L |
| Docket Text: | 1EPSTEINS MOTION COMPEL |
| 156 | RESP - RESPONSE TO: |
| Filing Date: | 16-OCT-2009 |
| Filing Party: | I M, L |
| Docket Text: | COMPEL |
| 157 | i REQ - REQUEST |
| Filing Date: | 22-OCT-2009 |
| Filing Party: | j EPSTEIN, JEFFREY |
| Disposition Amount: , | iC |
| Docket Text: | ITO PRODUCE |
| 158 | i NOH - NOTICE OF HEARING |
| Filing Date: | :22-OCT-2009 |
| Filing Party: | i CRITTON JR, ESQ, ROBERT DEWEESE |
| • Docket Text: | one. |
| 159 | RNTD - |
| Filing Date: | 26-OCT-2009 |
| Docket Text: | none |
| 160 | NOTD - |
| Filing Date: | 28-OCT-nos |
Disposition Amount: 1
Docket Text: inone.
. \_\_ \_\_\_\_\_, .\_
: 161 NOF - NOTICE OF FILING
Filing Date: 28-OCT-2009
Filing Party: CRITTON JR, ESQ, ROBERT DEWEESE
\[Disposition Amount
Docket Text: none. I j
-........ r
162 I MFSJ - MOTION JUDGMENT FOR SUMMARY ..S.\_.
Filing Date: 30-OCT-2009
filing Party: EPSTEIN, JEFFREY
Disposition Amount
Docket Text: none.
163 RESP - RESPONSE TO:
Filing Date: ,30-OCT-2009
Filing Party: I EPSTEIN, JEFFREY J
Disposition Amount: i
Docket Text: , PLT MOTION
\--
164 ORD - ORDER
Filing Date: \_102-NOV-2009
Filing Party:
Disposition Amount:
Docket Text: DENYING EMERGENCY MOTION-DHAFELE
165 I ORD - ORDER
Filing 03-NOV-2009
Filing Party: I \_
Disposition Amount: i j
Docket Text: liON PLTF'S MTN TO TERMINATE DEPOSITION-DENIED-DHAFELE
166 I ORD - ORDER
Filing Date: 03-NOV-2009
\:Filing Party:
| Disposition Amount: | | |
| -------------------------- | ---------------------------------------------- | --- |
| Docket Text: | ON MTN TO COMPEL-GRANTEDIN PART DENIED IN PART | |
| 167 | MOT - MOTION | |
| Filing Date: | 04-NOV-2009 | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | |
| Disposition Amount: | | |
| Docket Text: | FOR PROTECTIVE ORDER | |
| 168 | NOJT - NOTICE OF JURY TRIAL | |
| Filing Date: | 05-NOV-2009 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | CALENDAR CALL ON 04/30/10 | |
| 169 | SRSV - SUBPOENA RETURNED / SERVED | |
| Filing Date: | 05-NOV-2009 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | DR AMY SWAN-SERVED | |
| 170 | NOTD - NOTICE OF TAKING DEPOSITION | |
| Filing Date: | 05-NOV-2009 | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | |
| Disposition Amount: | | |
| Docket Text: | none. | |
| 171 | MOT - MOTION | |
| Filing Date: | 06-NOV-2009 | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | |
| Disposition Amount: | | |
| Docket Text: | none. | |
| 172 | SRSV - SUBPOENA RETURNED / SERVED | |
| Filing Date: | 12-NOV-2009 | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | |
| Disposition Amount: | | | |
| -------------------------- | --------------------------------- | --- | --- |
| Docket Text: | none. | | |
| 173 | SRSV - SUBPOENA RETURNED / SERVED | | |
| Filing Date: | 12-NOV-2009 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 174 | SRSV - SUBPOENA RETURNED / SERVED | | |
| Filing Date: | 12-NOV-2009 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 175 | NOH - NOTICE OF HEARING | | |
| Filing Date: | 12-NOV-2009 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 176 | NOH - NOTICE OF HEARING | | |
| Filing Date: | 12-NOV-2009 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 177 | MOT - MOTION | | |
| Filing Date: | 12-NOV-2009 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 178 | NOH - NOTICE OF HEARING | | |
| Filing Date: | 16-NOV-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| -------------------------- | --------------------------------------------------------------------------------------------------------------------- | --- | --- |
| Docket Text: | none. | | |
| 179 | MOT - MOTION | | |
| Filing Date: | 16-NOV-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 180 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 18-NOV-2009 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 182 | SRSV - SUBPOENA RETURNED / SERVED | | |
| Filing Date: | 30-NOV-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 181 | TCPY - TRUE COPY | | |
| Filing Date: | 01-DEC-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | ORDER FROM 4DCA 4D09-2409 AND 4D09-3001 DTD 11-19-09 PETITIONS FOR WRIT OF CERTIORARI ARE HEREBY DENIED ON THE MERITS | | |
| 183 | ORD - ORDER | | |
| Filing Date: | 02-DEC-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | ON MTN FOR PRESERVATION OF EVIDENCE-GRANTED IN PART AS STATED | | |
| 184 | ORD - ORDER | | |
| iFiling Date: | I 02-DEC-2009 |
| ------------------ | ---------------------------------- |
| Disposition Amount | j \_ |
| Docket Text: | 11ON MTN TO QUASH SUPEONA-GRANTED |
| 185 | ' NOAP - NOTICE OF APPEARANCE |
| Filing Date: | 16-DEC-2009 |
| I Filing Party: | EDWARDS, BRAD |
| Docket Text: | none. |
| 186 | I NOH - NOTICE OF HEARING |
| | 1 I |
| Filing Date: | 07-JAN-2010 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEVVEESEL) |
| Docket Text: | none. |
| 187 | j MCMP - MOTION TO COMPEL |
| \[Filing Date: | 12-JAN-2010 |
| Filing Party: | EPSTEIN, JEFFREY I |
| "pocket Text: | lipone |
| 188 | NOH - NOTICE OF HEARING |
| Filing Date: | :13-JAN-2010 |
| i Filing Party: | 1CRIT N JR, ESQ, ROBERT DEWEESE I |
| Docket Text: | none. |
| 189 | MCMP - MOTION TO COMPEL |
| Filing Date: | 13-JAN-2010 |
| Filing Party: | EPSTEIN, JEFFREY |
| Docket Text: | hone. |
| 190 | ORD - ORDER |
| Filing Date: | I14-JAN-2010 |
| Disposition Amount: | | |
| -------------------------- | --------------------------------------------------------------------- | --- |
| Docket Text: | ON DFT MOTION IS GRANTED DHAFELE | |
| 191 | RESP - RESPONSE TO: | |
| Filing Date: | 15-JAN-2010 | |
| Filing Party: | M, L | |
| Disposition Amount: | | |
| Docket Text: | none. | |
| 193 | RNOH - RE-NOTICE OF HEARING | |
| Filing Date: | 15-JAN-2010 | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | |
| Disposition Amount: | | |
| Docket Text: | none. | |
| 192 | MCMP - MOTION TO COMPEL | |
| Filing Date: | 19-JAN-2010 | |
| Filing Party: | EPSTEIN, JEFFREY | |
| Disposition Amount: | | |
| Docket Text: | (AMENDED) MOTION TO COMPEL DOCUMENTS RESPONSIVE TO REQUEST TO PRODUCE | |
| 194 | NOH - NOTICE OF HEARING | |
| Filing Date: | 19-JAN-2010 | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | |
| Disposition Amount: | | |
| Docket Text: | none. | |
| 196 | MCMP - MOTION TO COMPEL | |
| Filing Date: | 22-JAN-2010 | |
| Filing Party: | [REDACTED], BRAD | |
| Disposition Amount: | | |
| Docket Text: | none. | |
| 197 | ORSH - ORDER SETTING HEARING | |
| Filing Date: | 25-JAN-2010 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: APRIL 9 2009? DHAFELE | | |
| ----------------------------------------- | --------------------------------------- | --- |
| 198 | NOH - NOTICE OF HEARING | |
| Filing Date: | 25-JAN-2010 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | none. | |
| 200 | NOTD - NOTICE OF TAKING DEPOSITION | |
| Filing Date: | 25-JAN-2010 | |
| Filing Party: | EDWARDS, BRAD | |
| Disposition Amount: | | |
| Docket Text: | CROSS | |
| 201 | NOH - NOTICE OF HEARING | |
| Filing Date: | 26-JAN-2010 | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | |
| Disposition Amount: | | |
| Docket Text: | none. | |
| 199 | NOT - NOTICE | |
| Filing Date: | 27-JAN-2010 | |
| Filing Party: | M, L | |
| Disposition Amount: | | |
| Docket Text: | TO SET CAUSE FOR JURY TRIAL, UP 2/1/10. | |
| 202 | NOS - NOTICE OF SERVICE | |
| Filing Date: | 28-JAN-2010 | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | |
| Disposition Amount: | | |
| Docket Text: | 3RD SET OF INTERRO | |
| 203 | NOTD - NOTICE OF TAKING DEPOSITION | |
| Filing Date: | 02-FEB-2010 | |
| Filing Party: | | |
| Disposition Amount: | | |
**204** NOH - NOTICE OF HEARING
**Filing Date:** 02-FEB-2010
**Filing Party:** CRITTON JR, ESQ, ROBERT DEWEESE
**Disposition Amount:**
**Docket Text:** *none.*
**205** NOT - NOTICE
**Filing Date:** 03-FEB-2010
**Filing Party:** EPSTEIN, JEFFREY
**Disposition Amount:**
**Docket Text:** OF PSYCHOLOGICAL EXAMINATION OF PLTF
**207** NOTD - NOTICE OF TAKING DEPOSITION
**Filing Date:** 04-FEB-2010
**Filing Party:**
**Disposition Amount:**
**Docket Text:** (CROSS) OF BRADLEY [REDACTED]
**208** ORD - ORDER
**Filing Date:** 04-FEB-2010
**Filing Party:**
**Disposition Amount:**
**Docket Text:** ON AMENDED MOTION TO COMPEL-GRANTED IN PART DENIED PART- DHAFELE
**209** NOTD - NOTICE OF TAKING DEPOSITION
**Filing Date:** 05-FEB-2010
**Filing Party:** M, L
**Disposition Amount:**
**Docket Text:** OF JANUSZ BANASIAK
**210** NOTD - NOTICE OF TAKING DEPOSITION
**Filing Date:** 05-FEB-2010
**Filing Party:** M, L
' Docket Text: IVIDEO OF
211 NOTD - DEPOSITION NOTICE OF TAKING
Filing Date: 05-FEB-2010
-
.
Filing Party: M, L
Disposition Amount:
Docket Text: VIDEO OF JEFFREY EPSTEIN
212 NOT - NOTICE
Filing Date: :05-FEB-2010
Filing Party: 1M, L
— — ;Disposition Amount:
Docket Text: , OF WITHDRAWAL OF WAGE CLAI rJ
213 NOH - NOTICE OF HEARING
Filing Date: 05-FEB-2010
Filing Party: CRITTON JR, ESQ, RO ERT DEWEESE
,
Disposition Amount:
Docket Text: none.
214 , MCMP - MOTION TO COMPEL \_
---a--- Filing Date: 105-FEB-2010
Filing Party: CRITTON JR, ESQ, ROBERT DEWEESE —
Disposition Amount '',.. ,
SOCket Text none.
; ---\_\_--.7 ---ii.:--- ,1
215 RNOT - RE-NOTICE
Filing Date: ;08-FEB-2010 \_I
iFiling Party: j B
,Disposition Amount:
Docket Text: none. I
216 I RESP - RESPONSE TO:
Filing Date: ' 09-FEB-2010
Filing Party: CRITTON JR, ESQ, ROBERT DEWEESE
Disposition Amount:
217 RESP - RESPONSE TO:
—
Filing Date: I10-FEB-2010 I-7 .
Filing Party: M, L
Disposition 1 Amount:
. i Docket Text: !AMENDED
206 AGOR - AGREED ORDER
Filing Date: 11-FEB-2010 .
-----"C— \_\_\_\_\_\_\_\_\_\_.\_\_\_
Filing Party:
Disposition Amount: ,
CIN
Docket Text: DHAFELE
218 ORD - ORDER
,--
Filing Date: I 12-FEB-2010
Filing Party: 1
;Disposition Amount:
Docket Text: TO COMPEL IS GRANT H FELE
i 219 ! RNOH - NG
Filing Date: I
Filing Party: i
Disposition Amount
t Docket Text: none
220 ! RNOH - NG
Filing Date:
Filing Party:
Disposition Amount:
;Docket Text: I none
221 I RNTD - DEPOSITION RE-NOTICE OF TAKING
Filing Date: l 16-FEB-2010
i Filing Party: M, L
Disposition Amount: I
Docket Text: I VIDEO
| Filing Date: | 17-FEB-2010 |
| -------------------------- | ------------------------------------------------------- |
| Filing Party: | |
| Disposition Amount: | |
| Docket Text: | ON MOTION TO COMPEL-GRANTED AS STATED IN TEXT |
| 224 | MCMP - MOTION TO COMPEL |
| Filing Date: | 17-FEB-2010 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Disposition Amount: | |
| Docket Text: | none. |
| 222 | OBJ - OBJECTION |
| Filing Date: | 22-FEB-2010 |
| Filing Party: | M, L |
| Disposition Amount: | |
| Docket Text: | TO DFTS SUBPOENA (REDACTED PER AGREED ORDER DTD 2/9/10) |
| 225 | NOT - NOTICE |
| Filing Date: | 22-FEB-2010 |
| Filing Party: | BRAD |
| Disposition Amount: | |
| Docket Text: | none. |
| 226 | NOS - NOTICE OF SERVICE |
| Filing Date: | 25-FEB-2010 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Disposition Amount: | |
| Docket Text: | none. |
| 227 | MFPO - MOTION FOR PROTECTIVE ORDER |
| Filing Date: | 02-MAR-2010 |
| Filing Party: | |
| Disposition Amount: | |
| Docket Text: | AS TO THE DEPOSITION OF NADIA MARCNKOVA |
Filing Date: j 03-MAR-2010
Filing Party: L, L
Disposition Amount I
Docket Text: \]\[OF PLTS ANSWERS TO DFTS THIRD INTERROG
229 I MCMP - MOTION TO COMPEL
Filing Date: 03-MAR-2010
Filing Party-
Disposition Amount:
EPSTEIN, JEFFREY
Docket Text:
230
!none.
ORSH - ORDER SETTING HEARING
Filing Date:
Filing Party:
Disposition Amount:
04-MAR-2010
Docket Text: ON 05/25/10 RE:MOTION TO COMPEL ANSWERS TO PLTF'S 1ST REQUEST FOR PRODUCTION
231 NOH - NOTICE OF HEARING
-
Filing Date: 04-MAR-2010
Filing Party: CRITTON JR ,ESt OBERT DEWEESE
Disposition Amount:
\[Docket Text:
232 i NOTD - NOTICE OF TAKING \_a' DEPOSITION
— 109-MAR-2010
\_\_\_ L. -, ,Nia
Filing Date:
none.
Filing Party: CRITTON JR, ESQ, ROBERT DEWEESE
Disposition Amount:
Docket Text: none.
--' J
!1233 NOTD - NOTICE OF TAKING j DEPOSITION - - —
Filing Date: ,09-MAR-2010
Filing Party: jtailLTON JR, ESQ, ROBERT DEWEESE
Disposition Amount: '
Docket Text: 9none.
| 234 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| ----- | ------------------------------------ | --- | --- |
| ----- | ------------------------------------ | -- | -- |
| Filing Date: | 09-MAR-2010 | | |
| -------------- | ------------- | --- | --- |
| -------------- | ------------- | -- | -- |
| Filing Party: | | | |
| --------------- | --- | --- | --- |
| --------------- | -- | -- | -- |
| Disposition Amount: | | | |
| --------------------- | --- | --- | --- |
| --------------------- | -- | -- | -- |
| Docket Text: | none. | | |
| -------------- | ------- | --- | --- |
| -------------- | ------- | -- | -- |
| 235 | NOT - NOTICE | | |
| ----- | -------------- | --- | --- |
| ----- | -------------- | -- | -- |
| Filing Date: | 12-MAR-2010 | | |
| -------------- | ------------- | --- | --- |
| -------------- | ------------- | -- | -- |
| Filing Party: | EPSTEIN, JEFFREY | | |
| --------------- | ------------------ | --- | --- |
| --------------- | ------------------ | -- | -- |
| Disposition Amount: | | | |
| --------------------- | --- | --- | --- |
| --------------------- | -- | -- | -- |
| Docket Text: | OF WITHDRAWAL OF MOTION AND CANCELATION OF HEARING | | |
| -------------- | ---------------------------------------------------- | --- | --- |
| -------------- | ---------------------------------------------------- | -- | -- |
| 236 | NOS - NOTICE OF SERVICE | | |
| ----- | ------------------------- | --- | --- |
| ----- | ------------------------- | -- | -- |
| Filing Date: | 15-MAR-2010 | | |
| -------------- | ------------- | --- | --- |
| -------------- | ------------- | -- | -- |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| --------------- | ---------------------------------- | --- | --- |
| --------------- | ---------------------------------- | -- | -- |
| Disposition Amount: | | | |
| --------------------- | --- | --- | --- |
| --------------------- | -- | -- | -- |
| 237 | REQ - REQUEST | | |
| ----- | --------------- | --- | --- |
| ----- | --------------- | -- | -- |
| Filing Date: | 15-MAR-2010 | | |
| -------------- | ------------- | --- | --- |
| -------------- | ------------- | -- | -- |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| --------------- | ---------------------------------- | --- | --- |
| --------------- | ---------------------------------- | -- | -- |
| Docket Text: | FOR ADMISSION | | |
| -------------- | --------------- | --- | --- |
| -------------- | --------------- | -- | -- |
| 238 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| ----- | ------------------------------------ | --- | --- |
| ----- | ------------------------------------ | -- | -- |
| Filing Date: | 29-MAR-2010 | | |
| -------------- | ------------- | --- | --- |
| -------------- | ------------- | -- | -- |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| --------------- | ---------------------------------- | --- | --- |
| --------------- | ---------------------------------- | -- | -- |
| Disposition Amount: | | | |
| --------------------- | --- | --- | --- |
| --------------------- | -- | -- | -- |
| Docket Text: | none. | | |
| -------------- | ------- | --- | --- |
| -------------- | ------- | -- | -- |
| 239 | RESP - RESPONSE TO: | | |
| ----- | --------------------- | --- | --- |
| ----- | --------------------- | -- | -- |
| Filing Date: | 10 | | |
| -------------- | ---- | --- | --- |
| -------------- | ---- | -- | -- |
| Filing Party: | BRAD | | |
| --------------- | ------ | --- | --- |
| --------------- | ------ | -- | -- |
| Docket Text: | TO DFT'S MOTION FOR PARTIAL SUMMARY JUDGEMENT | | |
| -------------- | ----------------------------------------------- | --- | --- |
| -------------- | ----------------------------------------------- | -- | -- |
Filing Date: 02-APR-2010
Filing Party:
Disposition Amount:
Docket Text: none.
,BRAD
241 RESP - RESPONSE TO:
Filing Date:
Filing Party:
Disposition Amount:
Docket Text: j TO EPSTEINS MOTION FOR PARTIALAUMMARY JUDGEMENT
242 ' RESP - RESPONSE TO:
— —
-- Filing Date: I 19-APR-2010 \_
\_ \_
Filing Party: riv1, L
Disposition Amo_unt: . \_
Docket Text: REQUEST FOR ADM'S ...-- ----7 .-- ..---...
243 NOS NOTICE — OF SERVICE 1
tiFiling Date: 119-APR-2010
Filing Party: BRAD \_
Disposition Amount: i
Docket Text: )OF PL P)S UNVERIFIED ANSAWERS TO DFT
..
244 NOTD - DEPOSITION NOTICE OF TAKING
Filing Date: 28-APR-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: — Inane.
\_
245 MCMP - MOTION TO COMPEL
Filing Date: 28-APR-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: IANSWERS TO 4TH SET OF INTERRS
05-APR-2010
EPSTEIN, JEFFREY
246 MOT - MOTION
Filing Date: I28-APR-2010
4 Tiling Party: jEPSTEIN, JEFFREY
Disposition Amount: .,.\_ I1
Docket Te xt: FOR LEAVE TO SERVE ADDITIONAL INTERRS
247 NOH - NOTICE OF HEARING - ----C------mss- -
Filing Date: 30-APR-2010
Filing Party:
Disposition Amount:
Docket Text: ON 05/12/10
,
248 --,, NOH - NOTICE OF HEARING
Riling Date: 05-MAY-2010
Filing Party:
FDisposition Amount:---ii—
Docket Text: ON 05/11/10
- ------- . 249 1 NOTD - DEPOSITION NOTICE OF TAKING
1
iFiling Date: 05-MAY-2010
\[Filing Party:
Disposition Amount:
Docket Text •".°12.?: .. . ,..2\_. .\_ \_-.Elim ----- -
250 — NOH - NOTICE -- OF HEARING r - -
' Filing Date: 06-MAY-2010
Filing Party:
Disposition Amount:
Docket Text iON 05/10/10
251 , SRSV - SUBPOENA SERVED RETURNED /
Filing Date: 10-MAY-2010
IFiling Party: I
Disposition Amount: -- ------
Docket Text: ATO ASHLEY MCGUIRE GENERAL MANAGER -- - - --- - -
252 SRSV - SUBPOENA RETURNED / SERVED
LLL
| Filing Date: | 10-MAY-2010 |
| ------------- | --------------------- |
| Filing Party: | 1 |
| Docket Text: | A TO R/C DR. AMY SWAN |
| 253 | AGOR - AGREED ORDER | | | |
| ----- | --------------------- | --- | --- | --- |
| ----- | --------------------- | -- | -- | -- |
| Filing Date: | 11-MAY-2010 |
| ------------ | ----------- |
| | |
| Filing Party: | |
| ----------------------- | --- |
| Dispatch Agency: | 1 |
| Disposition Amount: | |
| -------------------------- | ------------------------------------------------------------------------------------------------ |
| Docket Text: | ON DFT'S MOTION FOR PARTIAL SUMMARY JUDGEMENT ON COUNT I OF 2ND AMENDED COMPLAINT-DENIED AS MOOT |
| 254 | ORSH - ORDER SETTING HEARING | | | |
| ----- | ------------------------------ | --- | --- | --- |
| ----- | ------------------------------ | -- | -- | -- |
Filing Date: 13-MAY-2010
| Filing Party: | |
| -------------------------- | --- |
| Disposition Amount: | |
| Disposition Amount: | |
| -------------------------- | ------------------------------------------------------------------------------------------------ |
| Docket Text: | CASE SET FOR CALENDAR CALL ON 09/17/10 -AT CALENDAR CALL CASE WILL BE SET FOR JURY TRIAL-DHAFELE |
| 255 | NOTD - NOTICE OF TAKING DEPOSITION | | | |
| ----- | ------------------------------------ | --- | --- | --- |
| ----- | ------------------------------------ | -- | -- | -- |
Filing Date: 13-MAY-2010
| Filing Party: | |
| -------------------- | --- |
| | |
| Disposition Amount: | |
| ------------------- | ------------ |
| Docket Text: | none. |
| 256 | NOTE - NOTICE OF TAKING | | |
| ----- | ------------------------- | --- | --- |
| ----- | ------------------------- | -- | -- |
Filing Date: 13-MAY-2010
| Filing Date: | 15-MAT-2010 |
| ------------- | ----------- |
| Filing Party: | |
| Disposition Amount: | |
| ---------------------------- | --- |
| ---------------------------- | -- |
Docket Text: *none*.
| 257 | ORD - ORDER | | |
| ----- | ------------- | --- | --- |
| ----- | ------------- | -- | -- |
**Filing Date:** 13-MAY-2010
| Filing Party: | |
| ------------------- | --- |
| Disposition Amount: | |
| | |
**Docket Text:** ON MOTION FOR LEAVE TO SERVE ADDITIONAL INTERRO-
D - ORDER
13-MAY-2010
nt:
ON MOTION TO COMPEL ANSWERS-
H - NOTICE OF HEARING
21-MAY-2010
CRITTON JR, ESQ, ROBERT DEWEESE
nt:
none.
TR - MOTION TO STRIKE
22-MAY-2010
EPSTEIN, JEFFREY
nt:
CASE FROM TRIAL DOCKET
TD - NOTICE OF TAKING\
POSITION
24-MAY-2010
nt:
DUCES TECUM
D - ORDER
25-MAY-2010
nt:
GRANTING MOTION TO STRIKE
V - SUBPOENA RETURNED /\
VED
01-JUN-2010
nt:
| 258 | OR |
| ------------------- | ---------- |
| Filing Date: | |
| Filing Party: | |
| Disposition Amount: | |
| Docket Text: | |
| 260 | NO |
| Filing Date: | |
| Filing Party: | |
| Disposition Amount: | |
| Docket Text: | |
| 259 | MS |
| Filing Date: | |
| Filing Party: | |
| Disposition Amount: | |
| Docket Text: | |
| 261 | NO
DEF |
| Filing Date: | |
| Filing Party: | |
| Disposition Amount: | |
| Docket Text: | |
| 262 | OR |
| Filing Date: | |
| Filing Party: | |
| Disposition Amount: | |
| Docket Text: | |
| 263 | SRS
SEF |
| Filing Date: | |
| Filing Party: | |
| Disposition Amount: | |
Docket Text: STEINBACHER -SERVED
264 I CMP - COMPLAINT
Filing Date: 01-JUN-2010
Filing Party: M, L
Disposition Amount:
\[Docket Text: SPLTF'S THIRD AMENDED COMPLAINT
265 MCMP - MOTION TO COMPEL
Filing Date: I _ 10-JUN-2010
Filing Party: EPSTEIN, JEFFREY Am%
Disposition Amount:
Docket Text: none.
267 I_ORD - ORDER
Filing Date: 14-JUN-2010
Filing Party:
Disposition Amount: / a-
Docket Text: ON PLTF'S MTN TOCOMPEL
268 EMDIS - MOTION TO DISMISS
Filing Date: 17-JUN-201Q.,
Filing Party: frFNe7tIELFIREY
Disposition Amount
Docket Text: \[none.
269 SRNS - SUBPOENA RETURNED / NOT SERVED
- 21H-441. Filing Date: 17-JUN-2010
Filing Party: \_
Disposition Amount:
Docket Text: i hone.
266 EMOT - EMERGENCY MOTION
Filing Date: 25-JUN-2010
Filing Party: , EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: FOR STAY OF DISCOVERY
\[271 'NOR - NOTICE OF HEARING IL
Filing Date: I 25-JUN-2010
Filing Party: • CRITTON JR, ESQ, ROBERT DEWEESE
,
Disposition Amount:
\:Dock;t Text: tON 06/29/10
270 OBJ - OBJECTION
Filing Date: 1 28-JUN-2010
Filing Party: INI,L 1
Disposition Amount:
Docket Text: j none. - —
272 NOS - NOTICE OF SERVICE -,---- — —
Filing Date: \_\_ 1 28-JUN-2010 'NW 1
Filing Party: , EDWARDS, BRAD
Disposition Amount:
I Docket Text: none
273 ; ORD - ORDER TI
Filing Date: 29-JUN-2010
Filing Party:
Disposition Amount:
Docket Text: PON EMOTA R '4\\Y OF DISCOVERY-GRANTED-DHAFELE
274 ' REQ - REQUEST I
Filing Date: Ir06-JUL-2010
- — — - Filing Party: EPSTEIN, JEFFREY
Disposition Amount: j
Docket Text: ITO PRODUCE _ 1
275 i STIP - STIPULATION
Filing Date: 23-JUL-2010
Filing Party:
Disposition Amount:
Docket Text: OF DISMISSAL WITH PREJUDICE
______________________________________________________________________
276 FDS - FINAL _ \_\_\_\_\_\_\_\_\_ DISPOSITION SHEET rI
\_\_\_\_\_\_\_ \_\_\_\_ i ..",
Filing Party:
Disposition Amount
Docket Text: 1 DAO-DHAFELE
DAO - DISPOSED AFTER OTHER 276
Filing Date: 1 20-OCT-2011 \_\_\_\_\_
Filing Party:
1 \_. _ \_\_\_\_ _ _ \_\_J Co.
Disposition Amount:
Docket Text: I DHAFELE
# Report Selection Criteria
Case ID: 502008CA028058XXXXMB
Docket Start Date:
Docket Ending Date:
# Case Description
Case ID: 502008CA028058XXXXMB
Case Caption: EW V JEFFREY EPSTEIN
Division: AB - GILLEN
Filing Date: Thursday, September 11th, 2008
Court: CA - CIRCUIT CIVIL
Location: MB - MAIN BRANCH
Jury: Y-Jury
Type: ON - OTHER NEGLIGENCE
Status: DAO - DISPOSED AFTER OTHER
# Related Cases
No related cases were found.
# Case Event Schedule
No case events were found.
# Case Parties
| Assoc | Expn Date | | | |
| ----- | --------------------- | -------- | ------------- | -------------------------- |
| a--1- | 271;;IT-1, JUDGE | AU | KEYSER, JUDGE | I Aliases: inone |
| | PLAINTIFF | A1516811 | E' W | Aliases: none Aliases: PT; |
| | ATTORNEY -J DEFENDANT | 05,42075 | | |
Go
| | 2009 | | | GREGORY M | | | |
| --- | ---- | --- | --------- | ---------------- | ------------------------------------------ | --------------- | ----------- |
| 5 | 3 | | ATTORNEY | 0224162 | CRITTON JR, ESQ,
ROBERT DEWEESE | Aliases: | none |
| 6 | | | DEFENDANT | @1654349 | [REDACTED] | Aliases: | none |
| 7 | 3 | | ATTORNEY | 0262013 | GOLDBERGER, ESQ,
JACK A | Aliases: | none |
| 8 | | | JUDGE | AB | GILLEN, JUDGE
JEFFREY DANA | Aliases: | none |
# Pocket Entries
| r----- Docket | |
| -------------------------------------- | -------------------------------------------- |
| Number | Docket Type i Book and Page No. Attached To: |
| \_\_\_\_\_ \_\_\_, 00000 - ADDITIONAL COMMENTS | i |
| Filing Date: | 11-SEP-2008 |
| Filing Party: Disposition Amount: | \_\_1 1 |
| Docket Text: | !\[none. 800FF - GAFF |
| Filing Date: | I 11-SEP-2008 |
| Filing Party: | i\[E, W Disposition Amount: i |
| , Docket Text: | inone. --, PE - PENDING |
| Filing Date: | , 11-SEP-2008 |
| Filing Party: Disposition Amount: | i |
| I | i |
| Docket Text: | none. | | |
| -------------------------- | --------------------------------- | --- | --- |
| 1 | CMP - COMPLAINT | | |
| Filing Date: | 11-SEP-2008 | | |
| Filing Party: | E, W | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 2 | CCS - CIVIL COVER SHEET | | |
| Filing Date: | 11-SEP-2008 | | |
| Filing Party: | E, W | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 3 | RQAD - REQUEST FOR ADMISSIONS | | |
| Filing Date: | 11-SEP-2008 | | |
| Filing Party: | E, W | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 4 | REQP - REQUEST TO PRODUCE | | |
| Filing Date: | 11-SEP-2008 | | |
| Filing Party: | E, W | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 5 | NOFI - NOTICE OF FILING INTERROGS | | |
| Filing Date: | 11-SEP-2008 | | |
| Filing Party: | E, W | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 6 | MOT - MOTION | | |
| Filing Date: | 11-SEP-2008 | | |
| Filing Party: | E, W | | |
| Disposition Amount: | | | |
| Docket Text: | TO PROCEED ANONYMOUSLY | | |
7 ISM'S - SUMMONS ISSUED _ 11 \_II
...., -.1
Filing Date: j 11-SEP-2008
Filing Party: EPSTEIN, JEFFREY
\_J
Disposition Amount: ...
Docket Text: 1. M-08-162543
RCPT - RECEIPT FOR PAYMENT
— - Filing Date: I18-SEP-2008
\_
-
- Filing Party: • E, W
Disposition Amount:
Docket Text: A Payment of -\$311.00 was made on receipt CAMB 43377.
8 •
I DNAE - ERROR DOCKET NBR ASSIGNED IN
Filing Date: 119-SEP-2008
- — - - -- - Filing Party:
Disposition Amount:
Docket Text:
. MOTION TO PROCEED ANY OUSLY, GRANTED. D E
-=--- 9 ' ORDG - ORDER GRANTING
Filing Date: 19-SEP-2008
Filing Party:
\[Disposition Amunt: o
Docket Text: 'MOTION TO PROCEED ANONYMOUSLY, GRANTED. D E
10 I NOAP - NOTICE OF APPEARANCE - -,-, I — "- - -gram= — ee.----eaga—amp
\[tiling Date: '
----i\* Filing Party: , CRITTON JR, ESQ, ROBERT DEWEESE
07-OCT-2008
Disposition Amount: i
Docket Text: I AS COUNSEL FOR DFT JEFFREY EPSTEIN.
11 MDIS - MOTION TO DISMISS
\_\_\_
Filing Date: :08-OCT-2008
Filing Party: EPSTEIN, JEFFREY
Disposition Amount: r
Docket Text:
, FOR MORE DEFINITE STATEMENT AND TO STRIKE DIRECTED PLT EVV'S COMPLAINT. - TO
I II
ND
H.
| 12 | RESP - RESPONSE TO: |
| ------------------- | ---------------------------- |
| lifing Date: | 116-OCT-2008 |
| Docket Text: | I |
| 13 | ORSH - ORDER SETTING HEARING |
| Filing Date: | , |
| Disposition Amount: | _....p._ |
| 14 | MDIS - MOTION |
| | TO DISMISS I |
| Filing Party: | EPSTEIN, JEFFREY |
| Filing Date: | 130-OCT-2008 |
| Filing Party: | EPSTEIN, JEFFREY |
| Disposition | Amount: |
| Docket Text: | none. |
| 16 | RPRS - REPLY/RESPONSE |
| 17 | RERQ - RESPONSE TO REQ FOR |
| | \_J 19-NOV-2008 |
| Docket Text: | qTO PLTF'S FIRST REQUEST |
[Redacted]
NOTIONS TO PLTF'S FIRST SET OF INTERROGS
DISMISSED [REDACTED] RANTED IN PART & DENIED ER. D E [REDACTED]
OBERT DEWEESE
ROGATORIES DIRECTED TO PLT.
E
BILITY
RAH [REDACTED]
| 18 | RESP - RESPONSE TO: |
| ------------------- | --------------------------------------- |
| Filing Date: | 19-NOV-2008 |
| Filing Party: | EPSTEIN, JEFFREY |
| Disposition Amount: | |
| Docket Text: | RESPONSE & OBJECT |
| 19 | ORD - ORDER |
| Filing Date: | 10-DEC-2008 |
| Filing Party: | |
| Disposition Amount: | |
| Docket Text: | ON DFT'S MOTION TO IN PART.....VIEW ORD |
| 20 | NOS - NOTICE OF SERVICE |
| Filing Date: | 11-DEC-2008 |
| Filing Party: | CRITTON JR, ESQ, RC |
| Disposition Amount: | |
| Docket Text: | FIRST SET OF INTERR |
| 21 | REQP - REQUEST TO PRODUC |
| Filing Date: | 11-DEC-2008 |
| Filing Party: | EPSTEIN, JEFFREY |
| Disposition Amount: | |
| Docket Text: | (DFT'S FIRST) TO PLT. |
| 22 | NOUN - NOTICE OF UNAVAILAB |
| Filing Date: | [REDACTED] 08 |
| Filing Party: | BRAD |
| Disposition Amount: | |
| Docket Text: | none. |
| 23 | CMP - COMPLAINT |
| Filing Date: | 29-DEC-2008 |
| Filing Party: | E, W |
| Disposition Amount: | |
| Docket Text: | (AMENDED) AS TO SA |
| 24 | MEXT - MOTION FOR EXTENSIO |
# II TIME
--,— — -- Filing Date: ' 30-DEC-2008 _ _ _ _ _ _ II — --
Filing Party: EPSTEIN, JEFFREY
Disposition Amount: ;
Docket Text: TO AMENDED COMPLAINT.
25 AGOR - AGREED ORDER
, -
Filing .--- E51E --- j 06-JAN-2009
Filing Party: r
Disposition Amount:
ION Docket Text: ,i DFT'S MOTION FOR EXTENSION OFilliaQSPOND TO AMENDED COMPLAINT, GRANTED. D E \_\_A
26 ' \_\_ MDIS - MOTION TO DISMISS
iFiling Date: t13-JAN-2009
Wiling Party: \_\_\_ _ \_\_\_\_ • EPSTEIN, JEFFREY
Disposition Amount: • ..,' ,
Docket Text: --, COUNT IV OF PLT'S AMENDED COMPLAINT AND MOTION TO STRIKE SPECIFIED ALLEGATIONS.
27 NOTD - DEPOSITION NOTICE OF TAKING
Filing Date: .14 -- — -- -- -JAN-2009
Filing Party: ,
\_
Disposition Amount:
Docket Text: t OF JEFFREY EPSTEIN C/O ROBERT D CRITTON JR ESQ.
28 t NOAP - NOTICE OF APPEARANCE
Filing Date: 16-JAN-2009
Filing Party: GOLDBERGER, ESQ, JACK A
Disposition Amount:
Docket Text: ' AS COUNSEL FOR OFT JEFFREY EPSTEIN.
29 ORSH - ORDER SETTING HEARING
Filing Date: JF23-JAN-2009
i Filing Party: 7
Disposition Amount: i
| 30 | RESP - RESPONSE TO: | |
| -------------------------- | --------------------------------------------------------------------------- | --- |
| Filing Date: | 26-JAN-2009 | |
| Filing Party: | E, W | |
| Disposition Amount: | | |
| Docket Text: | DFT'S MOTION TO DISMISS COUNT IV OF AMENDED COMPLAINT AND MOTION TO STRIKE. | |
| 31 | NOS - NOTICE OF SERVICE | |
| Filing Date: | 26-JAN-2009 | |
| Filing Party: | E, W | |
| Disposition Amount: | | |
| Docket Text: | OF PLT'S ANSWERS TO DFT'S INTERROGATORIES. | |
| 32 | RESP - RESPONSE TO: | |
| Filing Date: | 26-JAN-2009 | |
| Filing Party: | E, W | |
| Disposition Amount: | | |
| Docket Text: | DFT'S FIRST REQUEST TO PRODUCE. | |
| 33 | RNTD - RE-NOTICE OF TAKING DEPOSITION | |
| Filing Date: | 02-FEB-2009 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | (VIDEO) OF DFT JEFFREY EPSTEIN. | |
| 34 | RNTD - RE-NOTICE OF TAKING DEPOSITION | |
| Filing Date: | 06-FEB-2009 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | (SECOND) OF DFT JEFFREY EPSTEIN. | |
| 35 | NPNP - NOTICE OF PRODUCTION NON PARTY | |
| Filing Date: | 11-FEB-2009 | |
| Filing Party: | BRAD | |
| Disposition Amount: | | |
| IDocket Text: | (VIEW LIST. |
| ------------------- | ------------------------------------------- |
| 36 | MOT - MOTION |
| Disposition Amount: | ' |
| 37 u | NOF - NOTICE OF FILING |
| | ITO QUASH PLT'S NOTICE OF TAKING DEPOSITION |
| Filing Date: | 18-FEB-2009 |
| Filing Party: | riCRITTON JR, ESQ, ROBERT DEWEESE |
| Docket Text: | (AFFIDAVIT OF JACK A GOLDBERGER, ATTACHED. |
| 39 | NOH - NOTICE OF HEARING |
| Filing Date: | i 18-FEB-2009 |
| Filing Party: | I CRITTON JR, ESQ, ROBERVkWEESE |
| Docket Text: | ION 3/9/09 @ 8:45 AM. \_ |
| 41 | SMIS - SUMMONS ISSUED |
| Docket Text | ISM-09-040 |
| 42 | NOH - NOTICE OF HEARING |
| Filing Date: | I23-FEB-2009 |
| \`Filing Party: | 1DRITTONJR, ESQ, ROBERT DEWEESE |
| iDocket Text: | ION 3/9/09 @ 8:45 AM. |
| 43 | OBJ - OBJECTION |
| Filing Date: | 123-FEB-2009 |
| • Disposition | Amount.\_ |
| | WITHOUT DEPOSITION DIRECTED TO YELLOW CAB. |
| RCPT - RECEIPT FOR PAYMENT | | |
| --------------------------------- | ------------------------------------------------------------------------------------------------ | --- |
| Filing Date: | 24-FEB-2009 | |
| Filing Party: | E, W | |
| Disposition Amount: | | |
| Docket Text: | A Payment of -\$10.00 was made on receipt CAMB284289. | |
| 44 | RPRS - REPLY/RESPONSE | |
| Filing Date: | 25-FEB-2009 | |
| Filing Party: | EPSTEIN, JEFFREY | |
| Disposition Amount: | | |
| Docket Text: | TO PLT'S RESPONSE TO DFT'S MOTION TO DISMISS COUNT IV OF AMENDED COMPLAINT AND MOTION TO STRIKE. | |
| 45 | RESP - RESPONSE TO: | |
| Filing Date: | 09-MAR-2009 | |
| Filing Party: | E, W | |
| Disposition Amount: | | |
| Docket Text: | MOTION TO QUASH... | |
| 46 | ORD - ORDER | |
| Filing Date: | 12-MAR-2009 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | SPECIALLY SET HEARING ON APRIL 24, 2009 AT 9:00 AM (E FINE) | |
| 47 | MOT - MOTION | |
| Filing Date: | 17-MAR-2009 | |
| Filing Party: | EPSTEIN, JEFFREY | |
| Disposition Amount: | | |
| Docket Text: | TO REASSING AND/OR TRANSFER TO DIVISION AB. | |
| 48 | NOH - NOTICE OF HEARING | |
| Filing Date: | 20-MAR-2009 | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | |
| Disposition Amount: | | |
| Docket Text: | ON 04/07/09 | |
| 49 | ORD - ORDER | |
| Filing Date: | 20-MAR-2009 | | |
| -------------------------- | ------------------------------------------------------------------- | --- | --- |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | ON DFT'S MTN TO DISMISS CT IV OF AMENDED COMPLAINT-GRANTED-SEE TETX | | |
| 50 | MOT - MOTION | | |
| Filing Date: | 26-MAR-2009 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| Docket Text: | TO STAY AND OR CONTINUE ACTION | | |
| 51 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 30-MAR-2009 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 52 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 30-MAR-2009 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 53 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 30-MAR-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 54 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 30-MAR-2009 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| (Docket Text: | R/C CARP ON 04/28/09 |
| --------------------- | -------------------------------------- |
| 55 | NOTD - NOTICE OF TAKING DEPOSITION |
| j Filing Date: | 30-MAR-2009 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Docket Text: | OF THE R/C JFK MEDICAL CTR-SERVED |
| ; 56 | NOTD - NOTICE OF TAKING DEPOSITION |
| Filing Date: | 130-MAR-2009 |
| Filing Party: | ICRITTON JR, ESQ, ROBERT DEWEESE |
| Disposition Amount: I | l ; |
| | NOTD - NOTICE OF 1DEPOSITION I |
| 'Filing Date: | 30-MAR-2009 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Docket Text: | iOF DOMINIQUE HYPPOLITE ON 04/28/09 |
| I Filing Date: | |
| Docket Text: | i R/C PURE PLATINUM |
| 60 | 9 NOTD - NOTICE OF TAKING ' DEPOSITION |
| (Filing Date: | '130-MAR-2009 |
| -------------- | ------------------------- |
| Docket Text: | 1R/C TS LOUNGE |
| 61 | NOTD - NOTICE OF TAKING |
| , Filing Date: | 30-MAR-2009 |
| Docket Text | I R/C SPEARMINT RHINO |
| 62 | i NOTD - NOTICE OF TAKING |
| Filing Date: | 30-MAR-2009 |
| Docket Text: | jR/C VEGAS CABARET |
| 63 | NOTD - |
| Filing Date: | I30-MAR-2009 |
| Filing Party: | , |
| | 7"14/-c l‘, |
| Docket Text: | ,\[R/C CHEETAH PALM BEACH |
| 64 | NOTD - |
| Filing Date: | 30-MAR-2009 i |
| Filing Party: | \_1 |
| Docket Text: | R/C CURVES CABARET |
| 65 | NOTD - |
| Filing Date: | 30-MAR-2009 |
| iDisposition s | Amount: |
| 66 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| ---- | ------------------------------------ | --- | --- |
| ---- | ------------------------------------ | -- | -- |
**Filing Date:** 30-MAR-2009
**Filing Party:**
**Disposition Amount:**
**Docket Text:** R/C DUFFY'S RESTAURANT
| 67 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| ---- | ------------------------------------ | --- | --- |
| ---- | ------------------------------------ | -- | -- |
**Filing Date:** 30-MAR-2009
**Filing Party:** CRITTON JR, ESQ, ROBERT DEWEESE
**Disposition Amount:**
**Docket Text:** OF THE R/C OF THE BODY SHOP-ON 04/17/09
| 68 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| ---- | ------------------------------------ | --- | --- |
| ---- | ------------------------------------ | -- | -- |
**Filing Date:** 30-MAR-2009
**Filing Party:** CRITTON JR, ESQ, ROBERT DEWEESE
**Disposition Amount:**
**Docket Text:** OF THE R/C SOLID GOLD ON 04/17/09
| 69 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| ---- | ------------------------------------ | --- | --- |
| ---- | ------------------------------------ | -- | -- |
**Filing Date:** 31-MAR-2009
**Filing Party:**
**Disposition Amount:**
**Docket Text:** OF RC DIAMOND DOLLS
| 70 | NNAC - NOTICE -NAME/ADDRESS CHANGE | | |
| ---- | ------------------------------------ | --- | --- |
| ---- | ------------------------------------ | -- | -- |
**Filing Date:** 06 APR 2009
**Filing Party:** BRAD
**Disposition Amount:**
**Docket Text:** none.
| 71 | ANAD - ANSWER & AFFIRMATIVE DEFENSES | | |
| ---- | -------------------------------------- | --- | --- |
| ---- | -------------------------------------- | -- | -- |
| Filing Date: | 07-APR-2009 |
| -------------------------- | ------------------------------------- |
| Filing Party: | EPSTEIN, JEFFREY |
| Disposition Amount: | |
| Docket Text: | TO PLT AMENDED COMPLAINT |
| 72 | ORD - ORDER |
| Filing Date: | 09-APR-2009 |
| Filing Party: | |
| Disposition Amount: | |
| Docket Text: | ON MTN TO REASSIGN OR TRANSFER-DENIED |
| 73 | MCMP - MOTION TO COMPEL |
| Filing Date: | 09-APR-2009 |
| Filing Party: | EPSTEIN, JEFFREY |
| Disposition Amount: | |
| Docket Text: | none. |
| 74 | MCMP - MOTION TO COMPEL |
| Filing Date: | 09-APR-2009 |
| Filing Party: | EPSTEIN, JEFFREY |
| Disposition Amount: | |
| Docket Text: | none. |
| 75 | NOF - NOTICE OF FILING |
| Filing Date: | 14-APR-2009 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Disposition Amount: | |
| Docket Text: | none. |
| | SRTN - SERVICE RETURN (ATTACHED) |
| Filing Date: | 15-APR-2009 |
| Filing Party: | [REDACTED] |
| Disposition Amount: | |
| Docket Text: | NOT SERVED |
| 76 | RPRS - REPLY/RESPONSE |
| Filing Date: | 16-APR-2009 |
| Filing Party: | |
Docket Text: \_j TO PLIES RESPONSE
-- ----- _ \_\_\_ _ _ \_
77 CCPY - CERTIFIED COPY
Filing Date: _ _ \[ 2 0 - APR\_ - 2009
\_ \_\_\_ . \_\_\_\_
' Filing Party:
### Disposition Amount:
Docket Text: 1OF ORDER TRANSFERRING CASES TO AB
78 NORE - NOTICE OF REASSIGNMENT
Filing Date: 24-APR-2009 1
Filing Party: \_\[ \_
# \[Disposition Amount:
Docket Text: TO DIV AB JUDGE HAFELE
79 i RQCP - REQUEST FOR COPIES i
i
Filing Date: 24-APR-2009
— --- - - -
\_\_\_\_ \_\_
Filing Party: 1E, W
### \[Disposition Amount:
Docket Text: none
! 80 MCMP - MOTION TO CO
Filing Date: 01-MAY-2009
Filing Party: \_
### Disposition Amount:
Docket Text: OTION TO COMPEL AND FOR SANCTIONS
81 \[NCOM - NOTICE OF COMPLIANCE I
Filing Date: j 05-MAY-2009 r
Filing Party: EPSTEIN, JEFFREY
#### Disposition Amount: ..\_
I
Docket Text: j none.
82 1JMCMP - MOTION TO COMPEL i
Filing Date: !155-MAY-2009
Filing Party: 1E W
# Disposition Amount
| 83 | NOTD - |
| ------------------ | ------------------------------- |
| !Filing Date: | i 06-MAY-2009 |
| Docket Text: | L M |
| | (--- 1106-MAY-2009 |
| Filing Party: | f------ |
| Docket Text: | \_PANE DOE |
| 85 | MOT - M |
| Filing Date: | 9 |
| Filing Party: | , BRAD |
| Disposition Amount | 'Nit |
| Docket Text | FOR PROTECTIVE ORDER ' |
| 86 | MOT - MOTION |
| Filing Date: | AB -MAY-2009 |
| Filing Party: | !EDWARD, BR |
| Docket Text: | iFOR ECTIVE ORDER |
| 87 | MOT - MOTION |
| Filing Date: | , 07-MAY-2009 |
| Filing Party: | EDWARDS, BRAD |
| Docket Text: | FORPROTECTIVE ORDER |
| 88 | I NOH - NOTICE OF HEARING |
| | 1 11-MAY-2009 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Docket | ON 05/14/09 |
189 INOT - NOTICE _ _ _ _ II
Filing Date: ' 11-MAY-2009
Filing Party: IEPSTEIN, JEFFREY 1
Disposition Amount:
Docket Text: 1OF PROPOUNDING EXPERT INTERROGATORIES TO PLT
90 MCMP - MOTION TO COMPEL \_1
Filing Date: 11-MAY-2009
Filing Party: EPSTEIN, JEFFREY
--- --- Disposition Amount: j
Docket Text: -11Tne.
91 NOH - NOTICE OF HEARING — \_
Filing Date: 12-MAY-2009
Filing Party: \_
Disposition Amount:
Docket Text: 5/14/09 c
92----- MOT - MOTION
Filing Date: 112-MAY-2009
Filing Party: E, W
Disposition Amount:
Docket Text FOR PROTEC E ORDER
, r OBJ - OBJECTION
-- Filing Date: 13-MAY-2009
i Filing Party: _ BRAD
-- - --- I Disposition Amount: I
- ,i-Docket Text: I TO DEPOSITION
94 T RESP - RESPONSE TO:
!Filing Date: 1114-MAY-2009
Filing Party: E, W
Disposition Amount:
Docket Text: till OPPOSITION TO DFT MOTION
95 I SRSV - SUBPOENA RETURNED / Ii
(SERVED
I
| Filing Date: | ' 14-MAY-2009 |
| -------------- | ---------------------------------- |
| Docket Text: | i SERVED CARP |
| 96 | ORSH - ORDER SETTING HEARING |
| Filing Date: | 1 14-MAY-2009 |
| Docket Text: | 'FOR 5/22/09. D HAFELE |
| 97 | ORD - ORDER |
| Filing Date: | 15-MAY-2009 zia,1%,) |
| Filing Party: | 1 L) I |
| Docket Text: | \[GRANTED. D HAFELE. |
| 98 | NOH - NOTICE OF HEARING |
| Filing Date: | 15-MAY-2009 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Docket Text: | 5128/09 |
| I Filing Date: | 115-MAY-2009 |
| Docket Text: | 6/4/09 8:45AM |
| 100 | i NOH - NOTICE OF HEARING |
| Filing Date: | 18-MAY-2009 |
| Filing Party: | CRITT ON JR, ESQ, ROBERT D EVVEESE |
| Docket Text: | jr5/28 i |
| 101 | NOR - NOTICE OF HEARING |
| Filing Date: | 18-MAY-2009 |
| Filing Party: | i CRITTON JR, ESQ, ROBERT DEWEESE |
| Disposition Amount: | |
| --------------------------------- | ---------------------------------------- |
| Docket Text: | , 6/9/09 |
| 1102 | NOH - NOTICE OF HEARING |
| Filing Date: | 18-MAY-2009 |
| Filing Party: Disposition Amount: | ' CRITTON JR, ESQ, ROBERT DEWEESE |
| Docket Text: | \_J 6/10/09 |
| , 103 Filing Date: | SUP - SUPPLEMENT |
| ILFiling Party: | I RAD Disposition Amount: I .\_1 |
| Docket Text: | 'none. |
| 104 | NOF - NOTICE OF FILING — |
| Filing Date: | ' 21-MAY-2009 |
| ' Filing Party: | . EPSTEIN, JEFFREY Disposition Amount: ! |
| Docket Text: | —bone. |
| 105 | ORD - ORDER |
| ;Filing Date: | i22-MAY-2009 |
| Filing Party: | I si |
| Disposition Amount: | ' |
| Docket Text | IDENIED VIEW ORDER. D HAFELE. |
| 106 | NOF - NOTICE OF FILING |
| | l 't |
| • Filing Date: | 22 -MAY-2009 |
| 1 Filing Party: | , EPSTEIN, JEFFREY Disposition Amiunt:7 |
| Docket Text: | ITHE ATTACHED DOCUMENTS |
| 107 | • MOT - MOTION |
| Filing Date: Filing Party: | 27-MAY-2009 Disposition Amount: { |
| IDocket Text: | iTO DISQUALIFY I |
| | --r-- |
| --------------------------------- | ------------------------------------ |
| 1108 iv- | \[NON - NOTICE OF HEARING II 4 |
| Filing Date: | ,28-MAY-2009 i |
| Filing Party: Disposition Amount | CRITTON JR, ESQ\_ , ROBERT DEWEESE |
| Docket Text: L | ON 05/28/09 Tr— I er---- |
| 109 | RESP - RESPONSE TO. |
| I Filing Date: | 28-MAY-2009 |
| Filing Party: | , EPSTEIN, JEFFREY |
| Disposition Amount | : |
| Docket Text: | IN OPPOSITION TO PLT MOTION... t---- |
| j 110 | INOF - NOTICE OF FILING |
| fr iling Date: | 101-JUN-2009 |
| Filing Party:\_ \_\_\_\_\_\_ | ADS, BRAD sEDisposition Amount: 1 |
| Docket Text: | ITRANSCRIPTS DATED 05/O/09- |
| 111 | ' MOT - MOTION -,. |
| Filing Date: | 02-JUN-2009 I |
| Filing Party: | 1 |
| Disposition Amount: | ) |
| Docket Text: | I none. |
| 112 | RNOH - RE-NOTICE OF HEARING |
| Filing Date: | 02-JUN-2009 |
| Filing Party: Disposition Amount: | CTRL-I-TON JR, ESQ, ROBERT DEWEESE J |
| Docket Text: | 6/18/09 8:45 |
| 113 | NOS - NOTICE OF SERVICE |
| Filing Date: | 10-JUN-2009 i |
| Filing Party: Disposition Amount | E, W |
| .Docket Text: | !pone. |
| 1114 | IORD - ORDER |
| Filing Date: | 12-JUN-2009 |
| -------------- | ---------------------------------- |
| Filing Party: | ; E, W |
| Docket Text: | ^T I DENIED. O HAFELE. |
| r115 \_ | ORD - ORDER |
| Filing Date: | '19-JUN-2009 |
| !Docket Text: | ,IORVERRULED VIEW ORDER. D HAFELE. |
| 116 | MOT - MOTION |
| Filing Date: | ^ J 24-JUN-2009 |
| Filing Party: | i E, W |
| Docket Text: | FOR LEAVE TO ADD COUNT FOR |
| | ERY AND SEEK PUNITIVE I |
| , 117 | NOH - NOTICE OF HEARING |
| , Filing Date: | 25-JUN-2009 |
| IFiling Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Docket Text | ON 7/7/09./ |
| 118 | NOT \_NOTICE |
| Filing Date: | i 29-JUN-2009 I |
| r | i t‘ |
| Docket Text: | one. |
| 119 | AGOR - AGREED ORDER |
| Filing Date: | 01-JUL-2009 |
| likocket Text: | 102N DFTS MOTION "DHAFELE" |
| 120 | !FTRflFTER |
| Filing Date: | 01-JUL-2009 |
| | ‘ 1 |
| Filing Party: | I |
| --------------- | -------------------------------------- |
| Docket Text: | TO JUDGE HAFELE |
| 121 | AGOR - AGREED ORDER |
| iFiling Date: | 101-JUL-2009 |
| Filing Party: | \_, |
| Docket Text: | TO DFT'S MTN TO COMPEL |
| I 122 | IFORD - ORDER |
| Filing Date: | 01-JUL-2009 |
| i Docket Text: | \[ON DFT'S MTN TO COMPEL BETTER ANSWERS |
| 123 | ! SUP - SUPPLEMENT |
| • Filing Date: | \]01-JUL-2009 |
| ;Filing Party: | t |
| 1Docket Text: | 'ORDER |
| 124 | I ORSH - ORDER SETTING HEARING |
| | — JI |
| | "--- i Disposition Amount: |
| ;Docket Text: i | none. |
| 125 | RESP - RESPONSE TO: |
| Filing Date: | 114-JUL-2009 _ _ s |
| Filing Party: | .CRITTON JR, ESQ, ROBERT DEWEESE |
| Docket Text: | iMOTION FOR LEAVE |
| 126 | ' MCMP - MOTION TO COMPEL I |
| Filing Date: | 14-JUL-2009 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Docket Text: | none. |
| -------------------------- | ----------------------------------------- |
| 127 | ORD - ORDER |
| Filing Date: | 16-JUL-2009 |
| Filing Party: | |
| Disposition Amount: | |
| Docket Text: | ON MNT TO COMPEL-SEE ORDER |
| 128 | NOF - NOTICE OF FILING |
| Filing Date: | 16-JUL-2009 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Disposition Amount: | |
| Docket Text: | none. |
| 129 | NOF - NOTICE OF FILING |
| Filing Date: | 17-JUL-2009 |
| Filing Party: | EPSTEIN, JEFFREY |
| Disposition Amount: | |
| Docket Text: | EXHIBIT A |
| 130 | NOTD - NOTICE OF TAKING DEPOSITION |
| Filing Date: | 17-JUL-2009 |
| Filing Party: | |
| Disposition Amount: | |
| Docket Text: | (CROSS) ALFREDO RODRIGUEZ |
| 131 | NOT - NOTICE |
| Filing Date: | 24-JUL-2009 |
| Filing Party: | BRAD |
| Disposition Amount: | |
| Docket Text: | none. |
| 132 | NOF - NOTICE OF FILING |
| Filing Date: | 22-JUL-2009 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| Disposition Amount: | |
| Docket Text: | none. |
| 1133 | 1NOF - NOTICE OF FILING 1 |
| ----------------------------------------------- | ---------------------------------------------------------------------- |
| Filing Date: | ---128-JUL-2009 |
| Filing Party: Disposition Amount: | I CRITTON JR, ESQ, ROBERTr |
| Docket Text: | tnone. j |
| 134 | ORD - ORDER |
| Filing Date: Filing Party: Disposition Amount: | 31-JUL-2009 |
| Docket Text: | ION MTN FOR LEAVE-GRANTED |
| 135 | NOH - NOTICE OF HEARING |
| Filing Date: Filing Party: ipisposition Amount: | 10-AUG-2009 |
| Docket Text: | 8/20/09 |
| 136 | MOT - MOTION i |
| Filing Date: | 10-AUG-2009 — — |
| Filing Party: | LE, W |
| Disposition Amount ; | ). |
| Docket Text: | FOR STAY OF ORDERS I |
| 156 | i TCPY - TRUE COPY |
| Filing Date: Filing Party: | J 10-AUG-2009 Disposition Amount: 1 |
| Docket Text: | TO CONSOLIDATE FILED 8-4-09 IS GRANTED, CASE NUMBERS ARE 'CONSOLIDATED |
| 1r | NOH - NOTICE OF HEARING |
| Filing Date: | 9 |
| Filing Party: I Disposition Amount: | j BRAD |
| Docket Text: i | i MTN CAL |
Filing Date: 12-AUG-2009
iFilin Party: - 7E, W --J
Disposition Amount: I
Docket Text: I FOR ENTRY UPON LAND
139 MCMP - MOTION TO COMPEL
Filing Date: 113-AUG-2009
i Filing Party: TtEPSTEIN, JEFFREY
Disposition Amount:
tDocket Text: --------- COMPLIANCE W/COURT ORDER . . . .
140 NOH - NOTICE OF HEARING IL
Filing Date: 13-AUG-2009
Filing Party: CRITTON JR, ESQ, ROBERT DE ES
rDisposition Amount
Docket Text: none.
141 RPRS - REPLY/RESPONSE
Filing Date: i 13-AUG-2009
jF lii31::!Ltt:\_\_JEI?STEIN, JEFFREY
Disposition Amount: ; 41'
;Locket Text: IN OPPOS61O EW MOTION FOR STAY
142 NOTD - NOTICE OF TAKING
DEPOSITION
tfliling Date: 19-AUG-2009
j Filing Party:
Disposition Amount: — - -
Docket Text: OF LM C/O BRAD ESQ.
143 ANAD - ANSWER & AFFIRMATIVE
DEFENSES
iling Date: 19-AUG-2009
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: none.
| 144 | | NNAC - NOTICE -NAME/ADDRESS
CHANGE |
| -------------------------- | ----------------------------------------------------------------------------------------- | --------------------------------------------- |
| Filing Date: | 20-AUG-2009 | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | |
| Disposition Amount: | | |
| Docket Text: | none. | |
| 145 | ORD - ORDER | |
| Filing Date: | 24-AUG-2009 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | ON MOT FOR SPECIAL SET HEARING, DENIED. D HAFELE. | |
| 146 | ORD - ORDER | |
| Filing Date: | 24-AUG-2009 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | PLT'S REQUEST FOR ENTRY UPON LAND W/DRAWN, DT 8/20/09 D HAFELE | |
| 147 | ORD - ORDER | |
| Filing Date: | 24-AUG-2009 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | PLT'S MOTION FOR STAY GRANTED AS SET FORTH IN THE TRANSCRIPT, DTD 8/20/09 D HAFELE | |
| 148 | ORD - ORDER | |
| Filing Date: | 24-AUG-2009 | |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | ON MOT TO COMPEL, GRANTED AS FOLLOWS.....VIEW ORDER. D HAFELE. | |
| 149 | NOS - NOTICE OF SERVICE | |
| Filing Date: | 01-SEP-2009 | |
| Filing Party: | E, W | |
| Disposition Amount: | | |
| Docket Text: | none. | | |
| -------------------------- | ----------------------------------------- | --- | --- |
| 150 | OBJ - OBJECTION | | |
| Filing Date: | 14-SEP-2009 | | |
| Filing Party: | EPSTEIN, JEFFREY | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 151 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 17-SEP-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | SEE LIST | | |
| 152 | NOH - NOTICE OF HEARING | | |
| Filing Date: | 17-SEP-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 153 | NOH - NOTICE OF HEARING | | |
| Filing Date: | 17-SEP-2009 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 154 | MSTR - MOTION TO STRIKE | | |
| Filing Date: | 17-SEP-2009 | | |
| Filing Party: | EPSTEIN, JEFFREY | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 157 | NOH - NOTICE OF HEARING | | |
| Filing Date: | 25-SEP-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | OCT 1 2009 | | |
**Filing Date:** 28-SEP-2009
**Filing Party:** [REDACTED], BRAD
**Disposition Amount:**
**Docket Text:** *none.*
**158** NOH - NOTICE OF HEARING
**Filing Date:** 29-SEP-2009
**Filing Party:** CRITTON JR, ESQ, ROBERT DEWEESE
**Disposition Amount:**
**Docket Text:** *none.*
**159** MOT - MOTION
**Filing Date:** 29-SEP-2009
**Filing Party:** CRITTON JR, ESQ, ROBERT DEWEESE
**Disposition Amount:**
**Docket Text:** *none.*
**160** NOJT - NOTICE OF JURY TRIAL
**Filing Date:** 01-OCT-2009
**Filing Party:**
**Disposition Amount:**
**Docket Text:** *none.*
**161** RESP - RESPONSE TO:
**Filing Date:** 02-OCT-2009
**Filing Party:** E, W
**Disposition Amount:**
**Docket Text:** *none.*
**162** ORSH - ORDER SETTING HEARING
**Filing Date:** 05-OCT-2009
**Filing Party:**
**Disposition Amount:**
**Docket Text:** *none.*
**163** NOF - NOTICE OF FILING
| Filing Date: | 14-OCT-2009 | | |
| -------------------------- | ---------------------------------- | --- | --- |
| Filing Party: | EPSTEIN, JEFFREY | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 164 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 21-OCT-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 165 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 28-OCT-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 166 | MOT - MOTION | | |
| Filing Date: | 02-NOV-2009 | | |
| Filing Party: | EPSTEIN, JEFFREY | | |
| Disposition Amount: | | | |
| Docket Text: | FOR PARTIAL SUMMARY JUDGEMENT | | |
| 167 | OSJT - ORDER SETTING JURY TRIAL | | |
| Filing Date: | 05-NOV-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | CALENDAR CALL ON 04/30/10 | | |
| 168 | SRSV - SUBPOENA RETURNED / SERVED | | |
| Filing Date: | 05-NOV-2009 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | DR AMY SWAN-SERVED | | |
| 169 | NOTD - NOTICE OF TAKING | | |
# (\[DEPOSITION pp v
| Filing Date: | i 18-NOV-2009 |
| --------------- | -------------------------------- |
| , Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE |
| | 1DU TE RECORDS ONLY \_1 |
| , 170 | SRSV - SUBPOENA |
| 'Filing Date: | , 30-NOV-2009 |
| \[Docket Text: | j PRESIDENTIAL WOMENS CTR-SERVED |
| Fri | -----Th, AGOR - AGREED ORDER |
| Filing Date: | j 02-DEC-2009 \_\_\_, 1 |
| Filing Party: | I |
| Text: | none. |
| 172 | NOAP - NOTICE OF APPEARANCE |
| Filing Date: | 114 |
| {Filing Party: | EDWARDS, BRAD |
| Docket Text: | \[none |
| 173 | NOH - NOTICE OF HEARING ll |
| Filing Date: | j12-JAN-2010 |
| Filing Party: | "EDWARDS, BRAD |
| Docket Text: | \_Inoue. |
| 174 | NOH - NOTICE OF HEARING |
| Docket Text: | LAN 19 2010 |
| | 7r---- r- 7\\ |
| \[175 | MCMP - MOTION TO COMPEL |
| Filing Date: | 113-JAN-2010 |
| ----------------------- | ------------------------------------- |
| Filing Party: | lEPSTEIN, JEFFREY |
| Docket Text: | r)one. |
| 176 | RNOH - RE-NOTICE OF HEARING |
| Filing Date: | 15-JAN-2010 |
| Filing Party: | I1\_\_\_ |
| iDisposition | Amount: j |
| Docket Text: | PAN 26 2010 |
| 177 | ORD - ORDER |
| Filing Date: | 19-JAN-2010 |
| Itpisposition Amount: J | / IN |
| Docket Text: | ON MOTION TO COMPEL-GRANTED-DHAFELE J |
| 178 | ORSH - ORDER SETTING HEARING J |
| I Filin Date: | 25-JAN-2010 |
| Filing Party: | (S |
| Docket Text: | APRIL 9 2009? DHAFELE |
| 179 | NOT - NOTICE |
| Filing Date: | p_7,Aitrot3---- |
| Docket Text: | Oone |
| 180 | NOJT - NOTICE OF JURY TRIAL |
| | 27-JAN-2010 1 |
| Filing Party: | I E, W i |
| Docket Text: | none. — - — — |
| Filing Date: | 28-JAN-2010 |
| Filing Party: | CRITTON JR . ESQ, ROBERT DEWEESE |
| Disposition Amount | |
| ---------------------------------------------- | ------------------------------------------------------ |
| Docket Text | ;3RD SET OF INTERROG |
| 182 | I MCMP - MOTION TO COMPEL |
| Filing Date: | 05-FEB-2010 |
| ;Filing Party: | 1CRITTON JR, ESQ, ROBERT DEWEESE Disposition Amount: i |
| Docket Text: | inane. |
| 183 | ! NOH - NOTICE OF HEARING |
| Filing Date: | K5-FEB-2010 |
| Filing Party: Disposition Amount: | ..., |
| Docket Text: | Ii FEB 11 2010 I i |
| 184 | ORD - ORDER |
| Filing Date: Filing Party: Disposition Amount: | 12-FEB-2010 i |
| Docket Text: | TO COMPEL IS G D HAFELE |
| 185 | NOT - NOTICE |
| 'Filing Date: | • 22-FEB-2010, |
| riling Party: Disposition Amount: | \[EDWARD B |
| Docket Text: | inane. |
| 186 | NOS - NOTICE OF SERVICE |
| Filing Date: | 25-FEB-2010 |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE Disposition Amount |
| \[Docket Text: | none. |
| 187 | I NOS - NOTICE OF SERVICE |
| Filing Date: | 703-MAR-2010 |
| \[Filing Party: Disposition Amount | lE, W |
| Docket -Twit: | linone. |
| 188 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| ------------------- | ------------------------------------ | --- | --- |
| Filing Date: | 08-MAR-2010 | | |
| Filing Party: | CRITTON JR, ESQ, ROBERT DEWEESE | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 189 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 08-MAR-2010 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | OF E.W. 4/2/10 | | |
| 190 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 29-MAR-2010 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | TO R/C DR AMY SWAN | | |
| 191 | RESP - RESPONSE TO: | | |
| Filing Date: | | | |
| Filing Party: | RAD | | |
| Disposition Amount: | | | |
| Docket Text: | MOTION FOR PARTIAL SUMMARY JUDGEMENT | | |
| 192 | NOS - NOTICE OF SERVICE | | |
| Filing Date: | | | |
| Filing Party: | RAD | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 193 | RPRS - REPLY/RESPONSE | | |
| Filing Date: | 05-APR-2010 | | |
| Filing Party: | EPSTEIN, JEFFREY | | |
| Disposition Amount: | | | |
| IDocket Text: | ITO MOTION FOR PARTIAL SUMMARY JJUDGEMENT |
| ------------------- | ----------------------------------------- |
| 194 | MCMP - MOTION TO COMPEL |
| Filing Date: | 09-APR-2010 |
| Filing Party: _ \_.. | : |
| | EPSTEIN, JEFFREY _ I |
| Docket Text | IDEPOSITION |
| 195 | NOH - NOTICE OF HEARING |
| FFiling Date: | 09-APR-2010 |
| iFiling Party: | J CRITTON JR, ESQ, ROBERT DEWEESE |
| Docket Text: | none |
| 196 | I |
| Filing Date: | 20-APR-2010 |
| | --, -.,-,-- , |
| 197 | i NOTD - |
| Filing Date: | 28-APR-2010 |
| Filing Party: | CRITTON JR, ESQ. ROBERT DEWEESE |
| ,--,--- - , | |
| 198 | I MOT - MOTION |
| Filing Date: | X28 -L--- -APR-2010 |
| Filing Party: | EPSTEIN, JEFFREY I |
| Docket Text: | jFOR LEAVE TO SERVE ADDITIONAL INTERRS |
| 199 | MCMP - MOTION TO COMPEL 1--------- 1 |
| Filing Date | 28-APR-2010 |
| Filing Party: | \[EPSTEIN, JEFFREY |
| ' '--- - | |
| | ---- I I |
| Docket Text: | jikNSWERS TO 4TH SET OF INTERRS |
| ----------------- | --------------------------------------------------- |
| 200 | : NOH - NOTICE OF HEARING i |
| i Filing Date: | 1 30-APR-2010 |
| | —1 i Filing Party: ICRITTON JR, ESQ, ROBERT DEWEESE |
| 1D?c ket Text: | |
| | 5: 12-10 AT 8:45 AM |
| 201 | RNOT - RE-NOTICE |
| Filing Date: | 05-MAY-2010 |
| \`Docket Text: | OF E.W. J |
| 202 | j |
| Filing5aW): | 105-MAY-2010 |
| Docket Text: | CROSS, VIDEOTAPED ' |
| 203 | I AGOR - AGREED ORDER |
| rVIS Filit T-1.-- | 05-MAY-2010 |
| , Docket Text: | O TEIN MTN TO COMPEL-GRANTED-DHAFELE |
| 204 | i AGOR - A ORDER |
| Filing Date: | 05-MAY-2010 |
| Docket Text: | EON MOTION TO COMPEL DEPOSITION |
| 205 | I NOH NOTICE OF HEARING T "r----1 |
| Filing Date: | 05-MAY-2010 |
| Filing Party: | L |
| Docket Text: | MAY 11 2010 |
**Filing Date:** 06-MAY-2010
**Filing Party:**
**Disposition Amount:**
**Docket Text:** MAY 10 2010
207 NOS - NOTICE OF SERVICE
**Filing Date:** 06-MAY-2010
**Filing Party:** [REDACTED], BRAD
**Disposition Amount:**
**Docket Text:** *none.*
208 SRSV - SUBPOENA RETURNED / SERVED
**Filing Date:** 10-MAY-2010
**Filing Party:**
**Disposition Amount:**
**Docket Text:** TO ASHLEY MCGUIRE GENERAL MANAGER ON 4/29/10
209 SRSV - SUBPOENA RETURNED / SERVED
**Filing Date:** 10-MAY-2010
**Filing Party:**
**Disposition Amount:**
**Docket Text:** TO ASHLEY MCGUIRE GENERAL MANAGER
210 SRSV - SUBPOENA RETURNED / SERVED
**Filing Date:** 10-MAY-2010
**Filing Party:**
**Disposition Amount:**
**Docket Text:** TO R/C DR. AMY SWAN
211 RESP - RESPONSE TO:
**Filing Date:** 12-MAY-2010
**Filing Party:** E, W
**Disposition Amount:**
| 212 | ORSH - ORDER SETTING HEARING | | |
| ------------------- | ---------------------------------------------------------------------------------- | --- | --- |
| Filing Date: | 13-MAY-2010 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | CALENDAR CALL ON 09/17/10 CASE WILL BE SET FOR JURY TRIAL AT CALENDAR CALL-DHAFELE | | |
| 213 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 13-MAY-2010 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 214 | NOTD - NOTICE OF TAKING DEPOSITION | | |
| Filing Date: | 13-MAY-2010 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | none. | | |
| 215 | ORD - ORDER | | |
| Filing Date: | 13-MAY-2010 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | ON MOTION FOR LEAVE TO SERVE ADDITIONAL INTERROGRANTED-DHAFELE | | |
| 216 | NOH - NOTICE OF HEARING | | |
| Filing Date: | 22-MAY-2010 | | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | ON 05/25/10 | | |
| 217 | MSTR - MOTION TO STRIKE | | |
| Filing Date: | 22-MAY-2010 | | |
| Filing Party: | EPSTEIN, JEFFREY | | |
| Disposition Amount: | | | |
| Docket Text: | | CASE FROM TRIAL DOCKET |
| -------------------------- | ---------------------------------- | ------------------------------ |
| 218 | NOTD - NOTICE OF TAKING DEPOSITION | |
| Filing Date: | | 24-MAY-2010 |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | | STEINBACHER |
| 219 | ORD - ORDER | |
| Filing Date: | | 25-MAY-2010 |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | | GRANTING MTN TO STRIKE-GRANTED |
| 220 | SRSV - SUBPOENA RETURNED / SERVED | |
| Filing Date: | | 01-JUN-2010 |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | | SSTEINBACHER-SERVED |
| 221 | CMP - COMPLAINT | |
| Filing Date: | | 01-JUN-2010 |
| Filing Party: | | E, W |
| Disposition Amount: | | |
| Docket Text: | | PLTF'S THIRD AMENDED COMPLIANT |
| 222 | MCMP - MOTION TO COMPEL | |
| Filing Date: | | 10-JUN-2010 |
| Filing Party: | | EPSTEIN, JEFFREY |
| Disposition Amount: | | |
| Docket Text: | | none. |
| 223 | NOH - NOTICE OF HEARING | |
| Filing Date: | | 14-JUN-2010 |
| Filing Party: | | |
| Disposition Amount: | | |
| Docket Text: | ON 06/28/10 ! |
| -------------- | --------------------------------------------------------- |
| 224 | MDIS - MOTION TO DISMISS I |
| Filing Date: | 17-JUN-2010 |
| Filing Party: | EPSTEIN, JEFFREY 1 |
| Docket Text: | COUNTS I & II OF THIRD AMENDED COMPLAINT WITH PREJUDICE_J |
| 225 | I |
| Filing Date: | 17-JUN-2010 |
| Docket Text: | WILLIAM DUNCAN OWNER-SERVED r } 3 |
| 226 | NOS - NOTICE OF SERVICE i |
| Fling Date: | 28-JUN-2010 |
| Filing Party: | , BRAD |
| Docket Text: | none. 1 |
| 227 | REQ- REQUEST ' |
| Filing Date: | 06-JUL-2010 |
| Filing Party: | EPSTEIN, JEFFREY |
| Docket Text: | Inone t |
| I 228 | STIP - STIPULATION \[ |
| Filing Date: | \_\_ j 23-JUL-2010\_ |
| Docket Text: | OF DISMISSAL W/PREJUDICE UP 7/26/10 W/UNSIGNED ORDER |
| | : t DAC, - DISPOSED AFTER OTHER |
| Filing Date: | 29-JUL-2010 |
| ; | -- ------- --- - Disposition Amount: |
| , ---, ---..-- | |
| | --,-- -=•'s |
| 229 | ORD - ORDER | Book 024007 - Page
01427 | |
| -------------------------- | ------------------ | ------------------------------------------------- | --- |
| Filing Date: | | 29-JUL-2010 | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | | ADOPTING STIPULATION AND DISMISSING CASE D HAFELE | |
| 231 | STIP - STIPULATION | | |
| Filing Date: | | 29-JUL-2010 | |
| Filing Party: | | | |
| Disposition Amount: | | | |
| Docket Text: | | OF DISMISSAL | |
NOTA CERTIFIED COPY
### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/
Plaintiff,
Vs.
JEFFREY EPSTEIN, et al.
Defendant.
Related Cases:
08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811. 08-80893. 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
A
< 4\\
PLAINTIFF JANE DOE'S NOTICE THAT ADDITIONAL EVIDENCE OF EPSTEIN'S FRAUDULENT ASSET TRANSFERS WILL BE FILED SHORTLY AND MOTION FOR CONSIDERATION BY THE COURT OF MATERIALS IN DOCKET NUMBERS 282 AND 283 IN DETERMINING MOTION FOR APPOINTMENT OF A RECEIVER RESTRAINING FRAUDULENT ASSETS TRANSFERS AND INCORPORATED MEMORANDUM OF LAW
Plaintiff Jane Doeiii(Q,ase #80893), hereby gives notice to the Court that she will shortly be filing additional evidence of fraudulent asset transfers by Jeffrey Epstein and to move the 61!) to consider these materials and all of the materials found in Docket z...) Numbers 282 and 283 in determining whether to grant Jane Doe's Motion for Injunction Restraining Fraudulent Transfer of Assets (DE 165 in case no. 9:08-CV-80119).
### ADDITIONAL EVIDENCE OF EPSTEIN'S FRAUDULENT ASSET TRANSFERS WILL BE FILED SHORTLY
As the Court knows, on June 19, 2009, Jane Doe filed a motion asking for appointment of a receiver to take control of defendant Jeffrey Epstein's assets and to post a \$15 million bond to secure any potential judgment in this case (DE 165 in case no. 9:08-CV-80119). The motion alleged that Epstein was hiding hundreds of millions of dollars in assets in an effort to defeat any judgment that Jane Doe (and many other victims of his child sexual abuse) might obtain against him. On July 13, 2009, Epstein filed his response. Without specifically denying any of Jane Doe's allegations of fraudulent transfers, Epstein essentially argued that Jane Doe lack any proof of such transfers [DE 198].
Jane Doe filed a reply to Epstein's response on J 2009 [DE 217]. But, in addition to the information and arguments provided there, Jane Doe now wants to alert the Court to newly-discovered evidence bolstering her arguments regarding Epstein's fraudulent concealment of his assets. Yesterday (October 15, 2009) counsel for Jane Doe took the deposition of Larry Visoski, who has been Jeffrey Epstein's personal pilot for approximately 18 years, flying (for example) Epstein's Boeing 727 jet. Visoski declared that, in the last year, Epstein has transferred to him four very valuable cars and a boat and registered them in his (Visoski's) name. A transcript of the deposition will not be available until October 22, 2009. But in view of the extreme relevance of this information to Jane Doe's pending-motion, she wanted to advise the Court of the substance of this testimony immediately — and will provide precise quotations from the deposition as soon as it is available.
While a precise transcript is not yet available, counsel represents that during the deposition, Visoski testified that the four cars and the boat were Epstein's, but that they were registered in his (i.e., Visoski's) name. The cars are a Land Rover/Range Rover Sport 2008 that Epstein purchased in the last year; a Mercedes Benz CLK 2005; Jaguar X 2005; and a. F250 2008. The. F250 is apparently being kept on St.= Island. Visoski was not aware that the. F250 was registered in his name, although he was aware of the other vehicles that Epstein registered in his (Visoski's) name.
In addition, Visoski now has a 35-foot JVC Powerboat. Visoski indicated that the owner of the boat is LSJ LLC. "LSJ" stands for "Little St. John's" Island and the LLC is controlled by Epstein. The boat is now registered in Visoski's name.
In addition, Visoski, admitted that a 2003 Ferrari 575M, owned by Epstein, is currently being sold in his name for an asking price of \$159,000. The Ferrari is being sold in New York, where Epstein maintains a residence. See http://www.dupontreoistrv.com/autos/search/DRauSearchDetails.aspx?itemidra437771 website visited on Oct. 15, 2009). Visoski did not know why the car was being sold in his name, and although he found it curious and strange that all these title conveyances were taking place, he did not question Defendant Epstein's motives.
Visoski also testified that he received a Hummer automobile recently from Epstein.
Jane Doe will provide the relevant parts of Visoski's testimony to the Court when it becomes available next week and will ask the Court to consider this newly-discovered information in ruling on her motion for appointment of receiver to take control of Jeffrey's Epstein's assets. Because Epstein has recently given notice to the Court that the motion for appointment of a receiver has been pending for roughly 90 days [DE 347] and has asked for a prompt ruling on the motion, Jane Doe wanted to promptly alert the Court to this new information. Because this new information also provides additional evidence of on-going fraudulent transfers, Jane Doe would join Epstein and respectfully request a ruling on her motion for appointment of a receiver as quickly as the Court believes that it has the necessary information to rule. A quick ruling is necessary to avoid further concealment of assets by Epstein.
### THE COURT SHOULD REVIEW MATERIALS FILED IN DOCKET NUMBERS 282 AND 283 IN DETERMINING MOTION FOR APPOINTMENT OF A RECEIVER TO RESTRAIN FRAUDULENT ASSETS TRANSFERS
In ruling on Jane Doe's motion for appointment of a receiver, the Court should also consider additional evidence not available at the time that Jane Doe filed her motion — materials provided by Epstein in camera in DE 282 and DE 283.
As the Court is aware, Jane Doe propounded requests for production, requests for admission, and interrogatories to Epstein to confess his fraudulent transfer of assets. Epstein refused to answer any questions about his asset transfers on Fifth Amendment grounds. Jane Doe then filed motions to compel answers to these questions. See DE 194, DE 195 and DE 198.
Epstein filed responses to the motions to compel, asserting that he was confronted with a °substantial and real" threat of criminal prosecution if he answered the questions (among others). See DE 339, DE 342 and DE 343. In connection with his responses, Epstein cross-referenced sealed, ex parte submissions he had made in other pleadings in consolidated cases. Epstein represented that "as set forth in more detail in DE 282 and 283" responding to the requests from information about his asset transfers would reveal incriminating information. See DE 339 at 13.
Jane Doe now asks the Court to consider these two sealed submissions not only in connection with Epstein's argument that he need not respond, but also in connection with Jane Doe's motion for appointment of a receiver. If it is true — as Epstein represents — that these sealed submissions truly demonstrates that responding to questions about asset transfers poses a real risk of criminal prosecution, then that same information is obviously relevant to Jane Doe's motion for appointment of a receiver.
There is, of course, no barrier to the Court considering that information in ruling on Jane Doe's motion. Epstein filed the documents under seal not to keep them from the Court, but to keep them from Jane Doe. Moreover, there is no Fifth Amendment prohibition to considering the information. Epstein has chosen to voluntarily reveal the information for his purposes in prevailing on his arguments on his motion to compel. The Court should be consider the information not only on that motion but on other motions as well. And, in any event, 'the Fifth Amendment does not apply in civil cases . . . ." United States v. Scrivner, 167 F.3d 525, 535 (9th Cir. 1999). See U.S. Const. amend. V ("No person . shall be compelled in any criminal case to be a witness against himself . . .1') (emphasis added).
Finally, common sense suggests that the Court should consider the information in ruling on Jane Doe's motion for appointment of a receiver. Any other conclusion would essentially mean that the Court would have to turn a blind eye to a defendant who explains (in a sealed submission) how he is perpetrating an on-going fraud. The Court should not bless Epstein's effort to hide his assets. Instead, it should consider all of the information in the sealed submission and, after doing so, should promptly grant Jane Doe's motion for appointment of a receiver to prevent fraudulent transfer of assets.
# CONCLUSION
For all these reasons, the Court should consider the additional information described in this pleading in support of Jane Doe's motion for appointment, of a receiver to prevent fraudulent transfers of assets.
CO
/ aN.
Respectfully Submitted,
Bradl
Bradley J.
ROTHSTEIN R SENFELDT ADLER
Las Olas City Centre
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
Telephone (954) 522-3456
Facsimile (954) 527-8663
Florida Bar No.: 542075
E-mail: bedwardserra-law.com
DATED October 16, 2009
+6s
and
Paul G. Cassell
Pro Hac Vice
332 S. 1400 E.
Salt Lake City, UT 84112
Telephone: 801-585-5202
Facsimile: 801-585-6833
E-Mail: cassellp@law.utah.edu
# CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on October 16, 2009 I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who artuthorized to receive electronically filed Notices of Electronic Filing.
> /Th /s/ Bradley J. Edwards Bradley J. Edwards
### SERVICE LIST
Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida
Jack Alan Goldberger, Esq. Jooldberoereampa.com
Robert D. Critton, Esq. rcrittonekcIclaw.com
Isidro Manual Garcia isidrogarciaAbellsouth.net
Jack Patrick Hill iph@searcvlaw.com
Katherine Warthen Ezell KEzellepodhurst.com
Michael James Pike MPikeebelclaw.com
Paul G. Cassell cassellpabciciaw.com
Richard Horace Willits\
[lawyerswillits@aol.com](mailto:lawyerswillits@aol.com)
Robert C. Josefsberg\
[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com)
Adam D. Horowitz\
[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com)
Stuart S. Mermelstein\
[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com)
William J. Berger\
[wberger@rra-law.com](mailto:wberger@rra-law.com)
NOTA CERTIFIED COPY
#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
JANE DOE NO. 2, CASE NO: OS-CV-80119-MARRA/
Plaintiff,
vs.
JEFFREY F.PSTEIN,
Defendant.
JANE DOE NO. 3, CASE NO: 08-CV-80
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
JANE DOE NO. 4,
Plaintiff.
JEFFREY E ( S"
De
vs.
CASE NO: 08-CV-803110-MARItA/
CASE NO: 08-CV-80119-MARRA/JOHNSOA
JANE DOE NO. 5, CASE NO: 08-CV-803131-MARla
Plaintiff,
vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 6.. Plaintiff. vs. JEFFREY EPSTEIN, Defendant. JANE DOE O.7, vs. JEFFREY EPSTEIN, Defendant. A t& CO c
SE NO: 08-CV-80994-MARRA/
CASE NO: 08-CV-80993-MARRA/JOHNSON
CASE NO: 08-O1-80119-MARla
C.M.A., CASE NO: 08-CV-8081I -MA RRA/
Plaintiff,
vs.
JEFFREY EPSTEIN.
Defendant.
JANE DOE,
Plaintiff,
Vs.
JEFFREY EPSTEIN, et al.,
Defendants.
DOE II.
Plaintiff,
vs.
( Se Il itilir JEFFREY EPSTE DI, et al.,
Defendants.
04
C
CASE NO. 08-CV-80893-CiV-MARRa
LS I
CASE NO: 09-CV-80469-MARRA/
JANE DOE NO. 101, CASE NO: 09-CV-8059I-MARRA/
Plaintiff,
vs.
JEFFREY EPSTEIN.
Defendant.
JANE DOE NO. 102, CASE NO: 09-CV-80656-MARRAMOFiNSON
Plaintiff,
vs.
AS CA) ) JEFFREY EPSTEIN,
Defendant.
/
k \\
#### PLAINTIFF JANE DOE'S REPLY MEMORANDUM IN SUPPORT OF MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN AND TO POST A SIS MILLION BOND TO SECURE POTENTIAL JUDGMENT
Plaintiff, Jane Doe. files this Reply Memorandum in Support of her Motion, pursuant to Federal Rule of Civil Procedure 64, for appointment of a receiver to take charge of Epstein's property and to post a 15 'Ilion bond to secure any potential judgment in this case.
in Jane Doe's motion, Epstein is a billionaire who recently has been fraudulently transfarin his assets overseas and elsewhere with the intent to prevent Janc Doe (and possibly several dozen other victims of his sexual abuse) from satisfying any judgment they might obtain against him. In response, Epstein does not deny these allegations, but essentially argues: "Prove It ... If You Can." Jane Doe is willing to take up his challenge in three ways. First. in the face of a supported motion seeking protection against fraudulent transfers, Epstein cannot simply refuse to confirm or deny that he
CASE NO: 08-CV40119-MARRA/JOHNSON
is making them. Because he has failed to controvert Jane Doe's claims, they are deemed admitted. Second, in any event, Jane Doe has clear evidentiary support that Epstein is hiding his assets through an adverse inference from his Fifth Amendment invocations. That inference is entirely appropriate in this case, because Epstein has personal knowledge of the subject at hand (whether he is fraudulently transferring assets) and the inference is entirely reasonable on the facts ocsith c ecase. Third, in addition to the adverse inference. Jane Doe has a perfect circumstantial case the means, motive, and opportunity to hide his assets. u ent transfers: Epstein has
In view of this proof of fraudulent transfers. Rule of Civil Procedure 64 guarantees Jane Doe all available state law prejudgment tect her interests. Florida has adopted the Florida Uniform Fraudulent Transfer Act ( lyt a. Stat. Ann. § 726.101 et seq., which gives the Court power to appoint a receiver t of assets that are being fraudulently transferred. Epstein's argument that this Court lac a ability to make such an appointment conflates an ordinary case (where courts are relyan e control of a defendant's assets before entry of judgment) and a case in which frauduttin ers have been proven — in which case seizure of assets is entirely appropriate.
Given that the Court has the power to appoint a receiver, it should appoint a receiver. Jane Doe v\\ teed extremely serious allegations of sexual abuse against Epstein, which is likely to produce ubst4ntial judgment in her favor (not to mention judgments of a similar nature in several dozen other This Court should not allow Epstein to move hundreds of millions of dollars overseas before Jane Doe can obtain her judgment. but should instead appoint a receiver - now - to take control of Epstein's assets and to post a \$15 million bond with this Court on behalf of Epstein to satisfy any judgment that Jane Doe might obtain.
DEFENDANT ESIITEIN HAS NOT DISPUTED JANE DOE'S MATERIAL FACTS WITH HIS OWN MATERIAL FACTS, SO JANE DOE'S FACTS SHOULD BE ACCEPTED
CASE NO: 08-CV-80119-MARRA/JOHNSON
In her moving papers. Jane Doe provided 14 specific material facts. each supported by evidence. In response. Epstein choose to ignore most of the facts, resorting instead to generalized attacks that the facts are "irrelevant, speculative, and hearsay." Epstein's Memo. in Opp. (DE 198 at 5(. Epstein should not be permitted to proceed in this blunderbuss fashion. Epstein shoutcibe required to explain which of the 14 specific facts he disputes - and which he does not. Jrideed4tis failure to controvert the facts specifically should lead the Court to deem all of them admitted.
A specific response to each of Jane Doe's material facts is certainly eaoroach envisioned in this Court's rules. Local Rule 7.5.C.3 explains that, for summary judgment motions, that statements of material facts "shall correspond with the order and with the ''regraoh numbering scheme used by the movant . . . ." Additional facts "shall be numbered`8p` ~)plauEd at the end of the opposing party's statement of material facts . . ." Id. The 7 lone Iles that 1.O1 material facts set forth in the movant's statement filed and supported ui by Local Rule 7.5.0 will be deemed admitted unless controverted by the opposin 'element, provided that the Court finds that the movant's statement is supported by evidentle ord." Id.
The obvious under' raison for this point-counterpoint approach is to narrow the range of disputes presented to-the co rt. A party needs to provide a specific basis for contesting the proposed facts of the o de and, without such a basis, should not contest the fact. Epstein has short-circuited this p using to explain which of Jane Doe's facts he contests — and which he admits.
ously, some of Jane Doe's facts arc incontestable. For example, Jane Doe has asserted that she seeks more than \$50 million in damages and many other, similarly-situated defendants seek at least the same amount in similar lawsuits pending before this Court and Florida courts. Thus, Epstein is facing more than \$1 billion in damages claims. See Material Facts #1 and #4. If these facts are true, CASE NO: OS-CV-80119-AI ARRA/.
indeniable motive to fraudulently hide his assets. But Epstein sidesteps and refusing to say whether or not he disputes these (quite incontestable) facts.
Doe has alleged that Epstein has international contacts, having travelled nous persons as President Bill Clinton. Prince Andrew, and Donald Trump. Is t he has these international travels? Here again, it is impossible to tell because ted whether he is contesting or accepting these facts.
several of Jane Doe's facts, Epstein responds generally that they are supported Lion. For example. Epstein argues "[t]his appearance of extreme wealth and national financial matters is based on inadmissible hearsay . . . ." )8 at 61. Epstein does not deny the truth of these allegations. And, to tEllst he : 8S? r1:1 mrces for these claims are inadequate. Jane Doe has now filed ting evidence with a new, recently-obtained Declaration — from mE E~ste imself. e's Motion to Provide Recently-Obtained Affidavit of .. Epstein in 'acts Supporting Motion for Appointment of a ake Charge of E 213). This Declaration was signed by Esptein in Offer of 2002 and filed in Jum of l.aw in Opposition to Plaintiffs MotiOntorSummary Judgment filed in . N.A. v. .leffrey E. Epstein and Fulair ial Trust Company. Inc.. Index No. 02 nited States Southern Distric of w York. in which Epstein was named sident and Director of Fittr?S,Trust Co., Inc. as Defendant. A copy of the rovided to Defendant and is attached hereto as Exhibit "A.". In this Declaration penalty of perjury:
is President and Director of Financial Trust Company, Inc., a business that . financial and business consulting services from the U.S. Virgin Islands to its
& ASA
then Epstein has an obscures this point by
Similarly. Jan overseas with such fa Epstein contesting tha Epstein has not explain
With regard to by "hearsay" informa sophistication in inter Memo. in Opp. (DE I' that the supporting sc supplement her suppor See Plaintiff Jane Do Support of Material Property of Epstein \[D support of a Memoran the matter of Citibank Civ. 5332(SHS) in U individually and as Pr' Declaration has been p Epstein declares under
- That he provide clients.
CASE NO: 08-CY-80119-MARRAa
- That he has been a legal resident of the U.S. Virgin Islands since 1999, residing at Little St. James Island — a 70-acre island that he owns through a wholly-owned limited liability company.
- From 1987 through the date of the affidavit. Epstein was one of Citibank's most important individual clients. - I,,
- In 1999, Epstein and Citibank did a \$10 million deal together, followed by,.'-another similar SI0 million deal the next year. These deals involved Epstein borrowing \$20 million from Citibank and then immediately reinvesting them in-a' ft Citibank .. ' was touting. ., I ),
lic -1— Of course, all of these admissions fully support the claims that Jane Doelimade in her initial moving ',..,,,,\_,.., papers.
Presumably the reason for Epstein refusing to respo t foint to Jane Doe's facts is that he does not want to have to respond specifically to a position that he has fraudulently transferred assets in the past and is currently tra assets overseas — transfers that are being used to defeat any judgment that might be e nst him in this case. If Epstein were required to go point-by-point through Jane Doc' as the Local Rules envision — then Epstein's counsel would have to either sign a pleading sting that such fraudulent transfers are taking place or representing, as an officer of the eourCi that no such transfers are taking place. Far better, Epstein has apparently concluded, to simply duck the issue entirely by blustering in general about how some /\\ aspects of Jane Doeutre "speculative" or "irrelevant.- -=-.
Beca4se or,I Epstein's failure to provide specific material facts in opposition to the facts V a—} profferecrbtlime Doe, al/ of these facts should be taken as admitted.
#### JANE DOE HAS PROVIDED SUFFICIENT, UNREBUTTED PROOF THAT EPSTEIN IS FRAUDULENTLY TRANSFERRING ASSETS
#### Jane Doe Has Provided Sufficient Support of lkr Alleged Facts
In addition to Epstein's procedural failures, he has also failed to provide any substantive reason for the court to refuse to accept the facts. Many of the facts arc well supported by the affidavit of Paul
CASE NO: 08-CV40119-ERRAa led. To the extent that any of the information provided in the dem has now disappeared in view of the Declaration signed by e Court.
fraudulent transfers of assets overseas are also sufficiently tl rule, Jane Doe supported her allegations on this point with 'min," Local Rule 7.5.C.2, namely, Epstein's answers to her vies. When asked directly whether he was perpetrating such a Intent privilege against self-incrimination.
i the Court to draw the obvious adverse conclusion - that he is, overseas. Epstein concedes that the Court has the power to Memo. in Opp. at 8. He gamely maintains, however, that such ter the test laid out by United States v. Custer Battles. LIC 41
mang test for deciding whether a factfinder can mg is whether there is "a valid basis for asserting the ege."
mked during discovery, this validity issue is Hy resolved the burden rests squarely on Epsteih to ow the specific basis Jrrently-pending motions tosompel answers to her requests for • rid interrogatories. See. intiff Jane Doe's Motion to :quest for Admissions to Defendant \[DE 21I) (filed July 20, Lion to compel, the Court concludes that Epstein does not have Put asset transfers. then Epstein will have to explain where he tion can be resolved in light of specific explanations from
Cassell. Esq., that Jane Doe initially Cassell affidavit was hearsay, that pro Epstein that Jane Doe is providing to tl
The facts regarding Epstein's supportecCkAs envisioned by the loc t—specific materials "on file with the ( C nests for admissions and interrogat. fraud, Epstein invoked his Fifth
> Epstein's invocation should lea in fact, fraudulently transferring asset draw such an inference. See Epstein's an inference is somehow not proper um F.Supp.2d 628, 633 (E.D. Va. 2006).
> Custer Battles lays out a two-I draw an adverse inference. The first pit Id. at 633. "When the privilege is in• via a motion to compel." Id. Because for his invocation. Jane Doe has filed c admissions, requests for production. Compel Answers to Plaintiff's First R 2009). If after reviewing Jane Doe's m a valid basis for invoking privilege ab has transferred his assets and this in
CASE NO: 08-CI40119-MARRea
Epstein. If, on the other hand. the Court concludes that Epstein does have a valid basis for invoking privilege about asset transfers, then the Court will have concluded that Epstein "might be prosecuted in this country" for making fraudulent transfers. Custer Batiks. 415 F.Supp.2d at 633. The issue then arises about what the court should infer from this fact.
The second-prong of the Custer Banks test explains how the/Cow should resolve whether to draw the obvious inference against Epstein. The Court should linake)'a assessment lot\] whether the, i Ill requested inference, which \[is) a form of evidence. comPllies) with the Federal Rules of Evidence. Thus, any adverse inferences must be relevant, rptf86te, and not unfairly prejudicial, confusing. or cumulative." Id. at 634 (internal citation onfitfe..\\\* acl, q d in Epstein's Memo. in Opp. (DE 198 at 9). IN Surprisingly, having set out this governing. \\s itcn o . 2prong of the test. Epstein does not pause to analyze whether it is satisfied. Presumab because the test obviously is satisfied. The inference that Epstein is fraudulently transferring-Wets is plainly "relevant" to Jane Doe's motion to have the Court intervene to stop the fraucE\\Theitiference is likewise "reliable," because Epstein makes no argument 4..,'Nk-7 1, (nor offers any evicieneel/ to the contrary. And the inference is clearly "not unfairly prejudicial, 1. ,,. confusing, or cuMUtati(.4" because it goes to the central issue in this motion.
#### Thr,7fth Amendment Cases Do Nat Require Independent Evidence Before An Adverse Infetpnce Can Be Drawn
ather than analyze whether the inference satisfies the two-prong Custer Battles test, Epstein putts another sentence out of context from the opinion, which he claims forms yet a third prong of what Custer Battles itself describes as a "two step inquiry." Id. at 633. Epstein argues that an adverse inference can only be drawn when independent evidence exists of the fact to which the party refuses to answer. Epstein's Memo. in Opp. (DE 198 at 9). But that is not what Custer Battles actually says. Instead. Custer Battles discusses the need to show through independent evidence that an adverse inference satisfies the requirement of "personal knowledge" (one of the requirements for admissible
CASE NO: 08-CV-80115LERRa
case explains: "this finding of personal knowledge must itself nted at trial; a conclusion as to the reliability of an inference Norris' [the defendant's] seemingly blanket invocation of the 'usher Battles, 41 F.Supp.2d at 634-35 (emphasis added). Thus. ig inferences about oilier people's state of mind via an adverse cation of his Fifth Amendment rights. But the Court had no • regarding Morris' own state of mind: "This \[need for proof of ere, as none of the six deposition questions \[as to which Morris which there is any doubt about Morris' personal knowledge." about Epstein's personal knowledge about whether he himself hich is the narrow question that Jane Doe propounded in her n adverse inference would be entirely reliable and proper in th.
: also" citations in support of his claim that Ja '\`', fence" of his fraudulent transfers in order to gain the- nrerence irgan v. Hull, 932 F.2d 1572, 1580 (11rn Cir. 99i ), in which suit appealed from a district court_iJecision granting summary in that case had attempted t 0"tat \\d summary judgment by s had not complied With\\ Ise very and invoked the Fifth restions during discovery. The Eleventh Circuit, however, :he fact that several defendants had raised Fifth Amendment immary judgment grant: "Invocation of the fifth amendment cognizable inferences sufficient to preclude entry of summary
evidence under Fed. R. Evid. 602). Th rely on the other evidence to be prcs cannot derive by bootstrapping from privilege gainst self-incrimination." Bat . cautioned against drawi from defendant Morris' invi C 'Gully in finding an inference prope personal knowledge\] is not a problem took the Fifth\] inquire into matters as t Id. So too here: There can be no doub is fraudulently transferring assets — w requests for admission. Accordingly. a case.
> Epstein also provides two "set provide some kind of "independent web of fraudulent transfers. The first is Av Plaintiffs who had filed a frivolous lay judgment against them. The plaintiff arguing that several of the defendan Amendment in response to certain q rejected that claim by explaining that objections to discovery did not bar a s privilege did not give rise to any legal':
CASE NO: 08-CV-80119-MARRa
judgment. The negative inference, if any, to be drawn from the assertion of the fifth amendment does not substitute for evidence needed to meet the burden of production. Most importantly. Avirgan and Honey did not demonstrate that further discovery would have led to evidence which would have precluded summary judgment . . . . " Id. at 1580 (citing United States v. Rylander, 460 U.S. 752 (1983)). Avirgan thus stands for the unexceptional proposition that the mere fact that someone raised the Fifth Amendment does not prevent them from filing a well-supported summary jud motion. That principle has little application, however, to this case: here it is Jane Doe the moving party. Epstein has not provided any evidence that the Court should no an adverse inference — or, indeed, any evidence at nil in opposition to her motion. Accord.," g l, gan is not on ) ci7 point and certainly does not suggest that Jane Doe needs to provide son S ,% independent evidence to obtain an adverse inference.' 4.,
The other case cited by Epstein -- Eagle hospital Playic >v". SRC; Consulting. Inc., 561 F.3d 1298 (11th Cir. 2009) -- is likewise unavailing. ndant presented an affidavit to the district court that attached attorney-client privil s of the plaintiff company. When the company deposed the defendant in an effort to leAta. i6w he obtained these sensitive documents, the defendant took the Fifth. Based on these fa'ets alone, the district court drew the adverse inference that the plaintiff maintained the ability to monitor the company's confidential e-mails. On appeal, the Eleventh Circuit affirmed the district court's decision to draw an adverse inference. The Circuit explained that "Mhe tkitis-ton to invoke the Fifth Amendment does not have to be consequence-free." Id. Instead, a court need only avoid "an undue burden" on the constitutional invocation. An undue burden would exist from "(Wit automatic entry of an adverse judgment solely as a result of the
In addition, as explained below, Jane Doe has independent evidence via the circumstantial evidence of fraudulent transfers that she has provided to the Court, specifically the means, motive, and opportunity evidence.
#### CASE NO: 08-0'40119-MARRA/
at 1304. Similarly, "a dismissal following the assertion of the Rion where the inferences drawn from the Fifth-Amendment-Lute for the need for evidence on an ultimate issue of fact." Id. 64: either the "automatic entry of an adverse judgment" or "a ultimate fact." Rather. Jane Doe asks this Court to draw the is fraudulently transferring assets. That adverse inference then asking not for ultimate entry offinal judgment in her favor, but iver over Epstein's assets to preserve the status quo and prevent he end of the case, after paying whatever judgment the jury over his remaining assets. Therefore, drawing the inference as iurden Epstein with any conclusion of ultimate fact. but instead Hospital: "assign the proper evidentiary weight to \[Epstein'; Ata.,
\:an draw an adverse inference on the facts of this ixceedingly difficult for Jane Doc to get informat Wabout has previously recognized that "Ii)r) he fraudulent transfer I to the plaintiff, is more likely po s the particularized nduct." Special Purpose A.A. ceivabie Co-op Corp. v. L 4482611 (S.D. Ha. 200s k ;14., / arra, J.). Obtaining information its is particularly difficult, given his financial sophistication in ex. e.g.. Declaration of Jeffrey E. Epstein, Attachment I, at I is Island in the U.S. Virgin Islands through a wholly-owned in the Virgin Islands). Therefore, the Court should draw the
assertion of the Fifth Amendment." I Filth Amendment violates the Consti protected silence are treated as a subst
I e, Jane Doe does not prop di al" ed on a conclusion of ' Con adverse inference that Epstein C antes a linkin a chain of reasoning rather . any further fraudulent transfers. At returns, Epstein will then regain contra part of resolving this motion does not t does no more than was done in Eagle silence." Id. at 1304.
> The conclusion that the Court supported by common sense. It is Epstein's assets. Indeed, this Court context, . . . the defendant, as oppose information about the complained-of cc Prime One Capital Co.. .L.L.C, 2007 1,' about the whereabouts of Epstein's as: structuring control over those assets. (noting ownership of of Little St. Jatr limited liability company itself residen
CASE NO: 08-CV-80119-MARRA/
obvious inference that the reason Epstein is taking the Fifth when asked about his fraudulent transfers of assets is because he is making fraudulent transfers of assets.
# In Any Event, Jane Doe Has Provided Circumstantial Evidence of Epstein's Fraudulent Transfers
Even assuming, for sake of argument, that these cases could be read as establish' g me sort of requirement that Jane Doe produce independent evidence of fraudulent transfers obtai ing an adverse inference. Jane Doe has produced that evidence. As explained in detail ving papers. Jane Doe has a "perfect circumstantial evidence case that [Epstein] a[s] means, motive, and opportunity to fraudulently transfer assets." Jane Doe's Motion V rain Fraudulent Transfer of Assets at I I (quoting United States v. Sparks, 265 F.3d 825. 4 6' 44e0di . 20019! Epstein completely misses the point of Jane Doc's means, motive, and oppo n 1bAs" ment, construing it as some sort of new "test" for deciding whether asset transfers ar u ipt. See Epstein's Memo. in Opp. at \[DE c 198 at I9-20J. But Jane Doc otTers this ci ntial evidence not as a lest for determining a fraudulent transfer, but as evidence is making fraudulent transfers. Epstein cannot plausibly deny that he has the means. e, and opportunity to move all of his substantial assets overseas beyond the reach of Jan -Doe. This circumstantial evidence should be more than enough to meet whatever sort of burden.cif production Epstein wants to tease out of the adverse inferences cases.
,,- Indeed, takew n its logical conclusion, Epstein's argument about Jane Doe's purported need to \\ provide "independent evidence" of fraudulent transfers ultimately collapses under its own weight. Epsteirrsvould. apparently require Jane Doe to track down his fraudulent asset transfers to foreign countries, providing documentation of these fraudulent transfers. Of course, if she had clear
2 Epstein claims that the Sparks decision is "completely inapposite" because it concerns probable cause for an arrest, rather than a fraudulent asset determination. Epstein's Memo. in Opp. at 20. But the legal principle at stake that circumstantial evidence can provide strong proof — is the same regardless of the precise facts of the case. Indeed. if circumstantial evidence can be used at the basis for arresting a man and throwing him into jail (as in Sparks). then it would easily seem to provide a sufficient basis for the interim appointment of receiver to prevent fraudulent asset transfers.
CASE NO: 08-CV-80119-MARRA/
documentation of these transfers, there would be no need to rely on an adverse inference. In other words, Epstein's interpretation of the burden that Jane Doe must sustain to obtain an adverse inference would make the inference all but irrelevant.
Epstein's position also ignores the realities of this case. As Jane Doe proffered in her statement of facts, without direct response from Epstein, "Epstein has blocked all discovery.-in this and other related cases, regarding his assets." Jane Doe's Motion to Restrain Fraudulent cans tr of Assets at 8 (supported by uncontested affidavit of her legal counsel). Jane Doe had f her proffered that Epstein is a man of great financial sophistication, id. at 6 — a fact now undeniably supported by Epstcin's own affidavit. See Declaration of Jeffrey E. Epstein at 2, Attachment 1 (hearing under oath that Epstein provides financial advice from the U.S. Virgin Islands i unties and other matters to his clients and that he is viewed by Citibank as "one of its mos individual clients"). Given the fact that asset transfers can take place to such countries, Switzerland. and the Cayman Islands, placing the burden on Jane Doe to document f transfers to such destinations effectively gives a light to massive fraud — a d ould ultimately total in the neighborhood of one billion dollars (\$1,000,000,000.00). See lgoc's Motion to Restrain Fraudulent Transfer of Assets at [DE 165 at 5] (statement of literftfact that Epstein is a billionaire). The Fifth Amendment does not require such obtuSrtIts. Instead, it permits the narrow and reasonable inference that Epstein is fraudulently kansferring his assets, permitting the Court to take appropriate remedial action.
### -Drawing an Adverse Inference Would Not Violate the Fifth Amendment
Epstein also tries to argue that drawing an adverse inference on these facts would violate his Fifth Amendment rights. Epstein contends that "a judgment cannot rest solely upon a privileged refusal to admit or deny at the pleading stage." Epstein Memo. in Opp. \[DE 198 at I01 (quoting LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 391 (7th Cir. 1995) (emphasis added)). As just
CASE NO: 08-CV-80119.REA/JOHNSON
explained, Jane Doe has circumstantial evidence of fraudulent transfers. But more important for purposes of this argument. Jane Doe is not asking for a final judgment to be entered on Epstein's fraudulent transfer of assets. Instead, she is asking merely for an adverse evidentiary inference that then becomes a piece of evidence supporting her motion. In turn, her motion merely as for an interim measure that would protect the status quo: a receiver to account for E and prevent him from hiding them overseas.
ir Blocking fraudulent transfers is hardly the sort of "coercive' practiee that is of concern in the cases cited by Epstein. The cases are clear that using the Fifth Amendment to block discovery need not be "cost free." McKune v. Lite. 536 U.S. 24.41 (2002). Fiere.the iS no real cost to Epstein from the appointment of a receiver. All Jane Doe wants is a receiver to control Epstein's assets to keep them from dissipating overseas and to post a bond (in an interest-bearing account) to satisfy any judgment that she might obtain. These measures will only harm Epstein if he is attempting to \\ -- fraudulently transfer his assets outside the math of the Court. This is not the sort of burden that might N. even conceivably implicate true Elfin A ment concerns.
### b. Jane Doe Has Met the anotents to Obtain Relief Under Florida's Uniform Fraudulent Transfer Act
\\it/ 7 Somewhat ouloaer. Epstein argues in the tail end of his response that Jane Doe has failed to sufficiently prove fraudulent transfers under Florida's Uniform Fraudulent Transfer Act ("FUFTA"), Fla. Stat. §§,',726.141 et seq. Memo. in Opp. at \[DE 198 at 18211. Epstein argues that a fraudulent transfer is'-proven where: (I) a transfer of property has in fact occurred; (2) the property transferred belonged to the debtor; (3) the transfer occurred within certain statutory time periods; and (4) the debtor made the transfer with the intent to hinder, delay or defraud creditors. Memo. in Opp. at \[DE
CASE NO: 08•CV-801/9-MARRe
198 at 1131 (citing In re Leneve. 341 B.R. 53, 56 (Bkney S.D. Ha. 2006).1 However, Epstein does not grapple with the fact that Jane Doc has properly proven each of these four points with regard to the first factor — transfer of property — Jane Doe's Material Fact #9 is that Epstein has "conveyed money and assets in an attempt to insulate and protect his money and assets from being captu in civil lawsuits filed against him."
With regard to the second factor — that the property belonged to Jane Doe's Material Fact #9 and #12 (among others) is that he is moving his assets which total more than SI billion, according to Material Fact #8) overseas.
With regard to the third factor — that the transfers occ Jane Doe's Material Fact #9 is that the fraudulent tea fe kbilira been taking place "since he was incarcerated" (i.e., since June 2008) and Material that they are going on "currently." This on-going activity obviously satisfies whatever a pl ble time limits may apply.4 si w o'if! the appropriate time limits -
With regard to the fourth fact tein made the transfers with the intent to hinder. delay or defraud creditors — Jan? Doe Material Fact #9 is that Epstein has "conveyed money and assets in an attempt to insulate and protect his money and assets from being captured in civil lawsuits filed against him" and Matap act #12 is that "Epstein is transferring these assets with the intent to defeat any judg n at might be entered against him in this and other similar cases." Plainly Jane Doe has coy required elements of a case under the rurTA.' There is thus no need for the
.a..
Epsteitiincorrectly cites this case has having been decided by this Court (the U.S. District Court for the S.D. of Florida). when in fact it was decided by the Bankruptcy Court for the Southern District of Florida.
4 It is not clear that any time limit applies under the ruirrA. The ease cited by Epstein is a bankruptcy case. which refers to the need to prove that "\[title transfer was within one year of the date of the tiling of the \[bankruptcy! petition." See In re Leneve, 351 B.R. at 56. citing In re Ingersoll, 124 B.R. 116. 120 (M.D. Fla. 1991). The FUFTA eschews any rigid time limit if it can be shown that transfer was made with the "intent to hinder, delay, or defraud any creditor of the debtor." Ha. Stat. Ann. \*726.105(1Xa). Jane Doe has made such a showing, as explained in the next paragraph in text.
For this reason. Epstein's citation of In re Stewart, 280 B.R. 268, 285 (likricy. M.D. Fla. 2001). is not on point. In that case, the plaintiff had merely made allegations without providing any supporting evidence -
CASE NO: 08•CV-80119-MARRA/
Court to delve into the "badges of fraud" sometimes needed to determine fraudulent intent. See. e.g., In re Dealers Agency Services, Inc., 380 B.R. 608, 613 (Bkrtcy. M.D. Fla. 2007). Courts use these badges of fraud because it is, in some cases, "difficult to establish a transferor's actual intent." In re Rams:wax, 361 B.R. 246, 254 (Bkrtcy. M.D. Fla... 2006). Here, however, Jane Doe's a al facts establish the fraudulent intent. It could hardly be otherwise: Epstein has not al (m less proven) that he is moving his assets to overseas for any legitimate business pu
For all these reasons, the Court should conclude that Epstein is tly transferring his assets.
#### JANE DOE IS ENTITLED TO RELIEF TO BLOC FIN'S FRAUDULENT TRANSFERS UNDER THE UNIFORM FRAUDU TRANSFER ACT AS ADOPTED BY FLORIDA 1r'
In light of Epstein's fraudulent asset transfers, Jane 9oe is entitled to pre-judgment remedies to protect her. For purposes of navigating through the Court's PACER filing system, Jane Doe has checked the "injunction" box in the automateSsystem. But, as made clear in the body of Jane Doe's motion, while the relief can be viewed nn of injunctive relief, is more precisely viewed as a prejudgment seizure of property. In anyeant, the name is not important. See v. Cascade Intern., Inc., 21 F.3d 1520. 1530 ir. 1994) ("federal courts look past the terminology to the actual nature of the tell ted") (internal quotation omitted). Jane Doe's requested relief is specifically authorized I Rule of Civil Procedure 64,6 which guarantees Jane Doe during the course of
unlike Jane, who has provided an affidavit of counsel, adverse inferences from discovery propounded to Epstein. and circumstantial evidence of the mean, motive, and opportunity for fraudulent transfers. Moreover, in Stewart. that plaintiff did not "allege any specific fact which, even if admitted, would support a finding that transfer was made with the actual intent to defraud a creditor." Id at 286. Here, of course, that is precisely what Jane Doe has alleged and proven — all without any denial from Epstein.
Because Jane Doe is proceeding under Fed. R. Civ. P. 64 ("Seizure of Person or Properly) rather than Fed. R. Civ. P. 64 ("Injunctions"), she has not organized her brief around the well-known four factor test for obtaining injunctive relief. At the same time, however. her moving papers specifically discuss each of the four factors and it is obviously that she easily satisfies them. First, lane Doe has shown a likelihood of success on the merits. As explained in ha moving papers (see Jane Does Motion at 16-11). at trial she and several dozen young girls will all testify to a pattern of sexual abuse by
CASE NO: OR-C V-R0119-MARRa
this suit "all remedies providing for seizure of person or property for the purpose of securing satisfaction of the judgment ultimately to be entered in the action" that are "available under the circumstances and in the manner provided by the law of the state in which the court is held." The Rule goes on to provide that "(t)he remedies thus available include arrest, attachment, shment, replevin. sequestration, and other corresponding or equivalent remedies, howev Qignat and regardless of whether by state procedure the remedy is ancillary to an action or o fined by an independent action." This "tong-settled federal law provides\] that in all eral court . . . . state law is incorporated to determine the availability of prejud es for the seizure of person or property to secure satisfaction of the judgment ulti 21 F.3d at 1531. Accordingly, under this Rule, this Court looks to Flori la to ermine Jane Doe's rights to prejudgment relief! \\
To prevent fraudulent transfers of judgment, Florida has adopted the Uniform Fraudulent Transfer Act. Fla. Stat. . 01 et seq. Under Florida's Uniform Fraudulent Transfer Act (FUFTA), courts powered to take action to block fraudulent transfers of assets. Epstein attempts to obse power of this Court to block his fraud by arguing to the Court that "freezing a defendant to establish a fund with which to satisfy a potential judgment for money damages i an appropriate exercise of a federal district court's authority." Mem. in Opp.
Epstein as pled guilty to abusing some of these girls and has invoked the Fifth Amendment rather than answer any quest s a t it. Second. Jane Doe will obviously be irreparably hanned if Epstein succeeds in fraudulently transferring assets beyond the reach of this Court. has she will be unable to satisfy any judgment that she might obtain against him. Third. this injury clearly outweighs any injury to Epstein. as Epstein has not explained how he would he in any way harmed by the existence of a receiver whose job is merely to account for assets and block fraudulent transfers. Finally. such an injunction would serve the public interest. as it would prevent a billionaire sex offender from depriving Jane IThe (and his other victims) of compensation for the abuse he committed against them.
' Because Jane Doe is proceeding under Fed. R. Civ. P. 64, there is no requirement that she engage in a paper bby filing some sort of separate state law claim, as Epstein seems to argue. Man. in Opp. at II. See 21 F.3d at 1531 ("Rule 64 commands that the proper pretrial remedy to ensure that a fund will be avails le with which to satisfy a money judgment . . . is available according to the provisions of the forum state's law.").
CASE NO: 08-CV-80119-MARRa
[DE 198 at 12-13] (citing v. Cascade Intern.. Inc.. 21 F.3d 1520, 1531 (I 1 th Cir. 1994)). But Jane Doe stands not in the position of an ordinary tort claimant who is merely trying to gain a leg up on the collection of an anticipated judgment; instead, she is trying to block Epstein from altering the status quo by hiding all of his assets.
The difference between trying to gain an advantage in the collection proc us b king fraudulent transfers is widely recognized in the case law. For example, Epstein v. Cascade Intern., Inc., 21 F.3d 1520 (11th Cir. 1994) — refused to approv •gmcnt injunction seizing assets where the plaintiff had merely argued that this would c I collecting a judgment down the road. The Eleventh Circuit specifically recognized that f a ad en fers of assets presented an different problem:
Contrary to [plaintiff's] assertion, our hold\* to grant such preliminary injunctive powerless to protect a potential future with highly liquid assets, no matt caused, or how brazen its ane, contrary, Rule 64 of the Fe attachment of property for th\*' proper vehicle for plaintiff seek\] satisfying a potential money jAment. istrict court is without the power not mean that a federal court is remedy against a recalcitrant defendant ngful its conduct, how bad the injury it e judgment by secreting assets. On the f Civil Procedure authorizes the prejudgment of a plaintiff in certain situations and provides the to restrain a defendant's assets with an eye towards
21 F.3d at 1520. In this c course, Jane Doe is face with a brazen attempt by Epstein to hide his assets. She has plaintiffs i ded by proceeding under Rule 64, which calls the "proper vehicle" for
off point is Epstein's other main case - De Beers Canso!. Mines v. United States. 325 U.S. 212, 219 (1945) — in which the "Government disclairnfed\] any benefit of \[Federal Rule of Civil Procedure 641. which provides for an attachment . .. during the count of an action for the purpose of securing payment of any judgment" (emphasis added). Here, of course, far from "disclaiming" use of Fed. R. Civ. 64. Jane Doe is proceeding under it. The apparent reason that the Government
CASE NO: 08-C V-80119-MAR
disclaimed use of Rule 64 in De Beers was that it was not seeking any sort of money damages. See Ilanvorth v. Blinder. & Co.. Inc., 903 F.2d 186, 195 (3rd Cir. 1990) (explaining why De Beers is a peculiar case that "must be understood in its context"). In later cases, the Supreme Court has not hesitated to approve relief to prevent fraudulent dissipation of assets that migh satisfy a judgment awarding money damages. See, e.g.. United States v. First Nati U.S. 378, 385 (1965) (approving a temporary injunction to prevent "transfer\[ri distinguishing De Beers).
In one final attempt to obscure this Court's power, Epstein cy whop v. Mason, 611 So.2d 1367, 1368 (Fla. Ct. App. 1993). as rejecting plaintiff's on prohibit a defendant from transferring assets. Mem. in Opp. at 14. But the specific for rejecting the motion was that the plaintiffs were not proceeding "under the Uni F ulent Transfer Act." 611 So.2d at 1368. Of core, in this case, Jane Doe is proceed' g r Florida's Uniform Fraudulent Transfer Act, incorporated as a state law remedy into . P. 64.8
For all these reasons, the FUFTA. power to protect Jane Doe through the provisions of the
file an In her motion. Jane Doe sought appointment of a receiver to take charge of Epstein's accets, to nting of those assets, and to post a \$15,000.000 bond. Jane Doe explained that the Uniform Fraudulent Transfer Act gives this Court broad remedial powers to prevent fraudulent transfers of assets. The remedies provided by the Act include:
#### UNDER FLORIDA'S UNIFORM FRAUDULENT TRANSFER ACT. JANE DOE IS ENTITLED TO THE REMEDIES OF APPOINTMENT OF A RECEIVER TO TAKE. CHARGE OF EPSTEIN'S ASSETS. FILE AN ACCOUNTING OF THOSE ASSETS WITH THE COURT, AND TO POST A \$15 MILLION BOND
Epstein cites certain cases regarding the nature of affidavits and other proof that must be provided when a plaintiff proceeds under the general prejudgment attachment provisions found in Fla. Stat. § 76.01. See Mem. in Opp. at 15-16. Those requirements have no bearing on Jane Doe's motion, which proceeds under the FUFTA.
CASE NO: 08-CV-80119-MARRA/JOHISSON
- I. An injunction against further disposition by the debtor ... of the asset transferred . .
- •
- 2. Appointment of a receiver to take charge of the asset transferred or of other property of the transferee; or
- 3. Any other relief the circumstances may require. Fla. Stat. Ann. § 726.108(c).
In response, Epstein argues that this Court is powerless to appoint a receiver. becau section
A (2) of the FUFTA refers to a receiver to take control "of the asset transferred or of other proof the transferee." But Epstein does not deny that the Court obviously has the potter to appoint a receiver under section (3) of the FUFTA, which broadly confers power on court to a laJny other relief the circumstances may require." For this reason, it is not important that Ja shoehorn her claim within section (2). Instead, she can rely on (3), which is "a ' rase that allows courts to award "other relief." Freeman v. First Union Nat. Bank, 72, 1276 (Fla. 2004). The intent of this provision was "to facilitate the use of the presumably including receivers, since they are uss in the statute. The only question, then, is whether the "circumstances" here make in ent of a receiver appropriate. A receiver is the remedy that makes the most sense, kee t FtpTeceiver can identify where Epstein's assets are and can prevent further fraudulent transfe ies provided in the statute," id. --
Epstein does not e (much less, convincingly argue) that appointment of a receiver is inappropriate. Inst he di off on a detour regarding the circumstances in which fiduciaries can obtain an eq ac, ting. See Memo. in Opp. at 16-17. However, those cases allow an accounting e remedy at law is inadequate." Florida Software Systems. Inc. v. Columbia/HCA Helathc orp., 46 F.Supp. 1276, 1285 (M.D. Fla. 1999) (citing Kee v. National Reserve Life Insurance Co., 918 F.2d 1538. 1540 (1 I th Cir. 1990). If the Court denies Jane Doe's motion, then she will be completely without any remedy to bar Epstein's fraudulent transfers — leaving her with no
° A receiver to account for Epstein's assets also makes sense because there are more than twenty other plaintiffs with sexual abuse claims against Epstein. who may be similarly situated to Jane Doe. A receiver can block fraudulent transfers that would harm these victims as well.
CASE NO: 08-O/40119-MARILa
"remedy at law." Moreover. Epstein pretends that the only point of the receiver is to provide an itemized list of his assets, as though this were a mere accounting exercise. But the main point of the receiver is block further fraudulent transfers by exercising control over Epstein's assets. Jane Doe will not be comforted to get an accounting next year after trial showing that Epstein h ved his hundreds of millions of dollars to Swiss bank accounts, Israeli corporations, a man Island investment trusts. Instead, she wants a receiver appointed now to keep Epstein I perpetrating a billion-dollar fraud.
After the receiver is in place. Jane Doe also asks for the poiling of S15,000,000 bond. here again, Epstein quibbles about the Court's authority to order such - a award, without addressing the fact that this Court has broad power to give Jane Doe "\[ainylath \\re ref the circumstances may require." Fla. Stat. Ann. § 726.108(c). Such a bond is appropnate Witte circumstances here, particularly given that Epstein never contests Jane Doe's argument as. to why such a bond is a reasonable given the judgment she is likely to obtain. Seeptte Doe's Motion to Restrain Fraudulent 1 ransfer of Assets at \[DE 165 at 16-171.
#### TIIE COURT ALSO HAS EQUITABLE POWERS TO PREVENT FRAUDULENT TRANSFERS - - \_
For all thereakons juSt explained, the Court has specifically direct power to appoint a receiver under the FUFfA,"ButJane Doe also explained in her motion that the Court has additional equitable powers. At ida cases explain, the UFTA "grants the court equity powers to remedy ... fraud." Invo Florida. Inc. v. Somerset Venturer. Inc., 751 So.2d 1263, 1267 (Fla. Ct. Apps. 2000). The FUFTA's provisions are "supplement[ed]" by "the principles of law and equity." Fla. Stat. Ann. § 726.111. Epstein does not contest Jane Doe's argument that "equity will do what ought to be done." Jane Doe's Motion to Restrain Fraudulent Transfer of Assets at 17 (citing Sterling v. Brevard County. 776 So.2d 281, 284 (Fla. Ct. Apps. 2000)). The only question then is "what ought to be done?"
CASE NO: 08-CV-80119ala
Epstein's answer to that question, at least as can be inferred from his pleadings, is that he should be allowed to take the Fifth on all questions about his sexual abuse of Jane Doe and where his assets are, and then be left free to fraudulently transfer all of hundreds of millions of dollars of assets to such places as Switzerland, Israel. and tax havens in the Caribbean — ultimately leaving .lane Doe unable to obtain any financial compensation for the abuse he inflicted on her and the-financial losses that it he entails. This Court should not allow such an affront to Jane Doe victims of Epstein, a convicted sex offender) — not to mention the affront to the abil is Court to enforce any judgment the jury might ultimately return. When this Court p n equity, it "will not suffer a wrong to be without a remedy." Carina v. Minendoll: 147 o d, 172 (Fla. CI. Apps. 1962). Jane Doe asks for the straightforward relief of appoin g er to take control over Epstein's assets and make arrangement to prevent further f en nsfers. Jane Doe has explained precisely how the receiver should operate, providing a p order for the Court's consideration. Epstein has not argued that the proposed order is burda Me in any way or suffers from any flaws. Indeed, the Court can read his entire response-witftrincling any substantive reason why the Court should not take the obvious step of intervening_to block fraudulent movement of his assets overseas. Instead, Epstein raises alleged legal roadblocks and procedural requirements that somehow keep the Court from doing "what ought-lobe done."
\\\`/- For 41 the'reasons explained here and in Jane Doe's opening papers, the Court should do what equity-- It should reject Epstein's makeweight arguments and intervene to block Epstein's fraud by appointing a receiver to take charge of his assets.
#### CONCLUSION
WHEREFORE, in view of the fraudulent transfers being made by Jeffrey Epstein to prevent Jane Doe from satisfying any judgment she might obtain in this case, the Court should appoint a Case 9:08-cv-80119-KAM Document 217 Entered on FLSD Docket 07/23/2009 Page 25 of 26
CASE NO: 08-CV40119-MA Rita
receiver to take charge of Epstein's property and direct the receiver to provide the Court with an accounting of Epstein's assets and post a \$15 million bond to secure any potential judgment that Jane Doe might obtain in this case.
404 1
DATED July 23, 2009 Respectfully Submitted,
ROTHSTEIN ROSENI;EI.DTµ1DLER Las Olas City Centre 401 East Las O Fort Laude Telephon 5 Facsim' Fl ,.,Suite 1650 a 33301 456 7-8663 542075 law c
...,SSul t G. Cassell Pro Hac Vice 332 S. 1400 E. Telephone: 801-585-5202 Salt Lake City, UT 84112 Facsimile: 801-585-6833 E-Mail: cassell oar law .titah.edu
C
'fill\*
#### CERTIFICATE OF SERVICE
I H DY ERTIFY that on July 23, 2009. I electronically filed the foregoing document with the CI •urt using CM/ECF. I also certify that the foregoing document is being served this day on ies on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing.
CASE NO: 08-CV-80119-MARRA/[REDACTED]
**SERVICE LIST**\
**Jane Doe v. Jeffrey Epstein**\
**United States District Court, Southern District of Florida**
Jack Alan Goldberger, Esq.\
[jgoldberger@agwpa.com](mailto:jgoldberger@agwpa.com)
Robert D. Critton, Esq.\
[rcritton@bclclaw.com](mailto:rcritton@bclclaw.com)
Isidro Manual [REDACTED]\
[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net)
Jack [REDACTED]\
[iph@searcylaw.com](mailto:iph@searcylaw.com)
Katherine Warthen Ezell\
[KEzell@podhurst.com](mailto:KEzell@podhurst.com)
Michael James Pike\
[MPike@bclclaw.com](mailto:MPike@bclclaw.com)
Paul G. Cassell\
[cassellp@bclclaw.com](mailto:cassellp@bclclaw.com)
Richard Horace Willits\
[lawyerswillits@aol.com](mailto:lawyerswillits@aol.com)
Robert C. Josefsberg\
[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com)
Adam D. Horowitz\
[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com)
Stuart S. Mermelstein\
[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com)
William J. Berger\
[wberger@rra-law.com](mailto:wberger@rra-law.com)
PLAINTIFF JANE DOE'S REPLY MEMORANDUM IN SUPPORT OF MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN AND TO POST A SIS MILLION BOND TO SECURE POTENTIAL JUDGMENT
CASE NO: 08-CV-80119-MARRAZIOUNSON
04
# tiw EX I4 IT A
A÷o's
#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
CITIFIANK,N.A., •
Plaintiff
v.
JEFFREY E. EPSTE1N and FINANCIAL TRUST COMPANY, INC.,
Defendants.
Index No. 02 Civ. 5332(SHS)
### DECLARATION OF JEFFREY E. EPSTEIN
JEFFREY E. EPSTEIN declares under penalty of perkiry pursuant to 28 U.S.C. §1746 that the following is true and correct:
- I. I am one oldie Defendants in the above-captioned action and the sole shareholder, the President and a Director of Defendant Financial Trust Company, Inc. ("FTC/') and make this Declaration based upon my personal knowledge of the facts set forth herein. I submit this Declaration in opposition to Plaintiff's Motion for Summary Judgment.
- 2. 1 have been a legal resident of the U.S. Virgin Islands since 1999. 1 reside at Little St. James Island, in the U.S. Virgin Islands, which is an approximately 70 acre island that I have owned, through a wholly-owned limited liability company, since 1998.
- 3. Tarn registered to vote and have voted in the U.S. Virgin Islands. I have a current and valid U.S. Virgin Islands driver's license and firearms license, and maintain a personal bank account and IRA account in the U.S. Virgin Islands.
- 4. Through my wholly-owned limited liability company, which is also resident in the U.S. Virgin Islands, I employ approximately 20 people, maintain two more bank accounts, own two cam and three boats and maintain several telephone numbers, all in the U.S. Virgin Islands.
5. My only business is a U.S. Virgin Islands corporation organized in the U.S.
Virgin Islands in 1999 as "Financial Trust Company, Inc.- FTC, Maitilailis its principal and only • .place of busiwas, consisting of 2800 square feet of office space. in St. tlinnins. V.S. Virgin Islands. MI eleven of FICI's employees. including myself. are U.S. Virgin Islands residents. .• • FTCI is qualified tinder the U.S. Virgin islands Economic Development Commission. as, authorized under the laws of the U.S. Virgin Islands.
-\\Y 6. FTC't maintains three local bank =Counts. a local IRA account mad its books and records in the U.S. Virgin islands. Between May 1999 and March 2002r. VIVI maintained Alio hank accounts with the St.= branch of Citibank. \_
7. FTCI is engaged in the business of providing financial and business consulting services from the U.S. Virgin Islands to its clients. In connection with its consulting business-FTCI makes investments in securities and other investments which we reasonably expect to be profitable and appropriate for ourselves and our clic-nss.
S. My business dealings andrelationsbip with Citigroup and its predecessor. Citicorp. date back to the 198O's. lbecame n client of the Citibank Private Bank in or about 1987. For approximately 15 years, Citicorp. Citibank and. ultimately. Citigroup provided banking and financial services to me and my business clients, through the ('itibunk Private Bank. • which. upon information and belief, changed its name to the Citigroup Private Bank some time in 2001 (collectively, "Citigroup" or the "Private Bank"). The Citigroup "relationship manager" responsible for iliac services during most of that period was Dayle Davison.
9. In early 1999.1 learned from Ms. Davison, an employee of the Private Bank. that Citigroup had targeted me as one of its most important individual clients and was seeking to
•
I
i
capitalize on its longstanding, relationship with me to persuade me to purchase a wide array of •• additional financial products and financial services, which were now available from Citigroup.
10. Citibank began the hard-sell of their new products and services in or around lam April of 1999, while I was in the U.S. Virgin Islands. At that time Citibank first introduced me to what was characterized as an exceptional investment opportunity involving a fund to be managed by MG Global Investment Corp. ("Ala"). in a series of telephone calls which I received in the U.S. Virgin islands between on or about April 20, 1999 and on or 1999, employees of the Private Bank, including Ms. Davison, aggressively solicited my -%;? participation in this "oppominity" ultimately resulting in a substantial investment by FEU in the amount of S10 million (the "MG Investment").
• •
11. During that period, I remember telephone c e zfona with Ms. Davison, in which she counseled me to subscribe for the AIG Investment. told me that it was an exceptional opportunity which has already generated so much preliminary interest that it will be substantially over-subscribed. Ms. Davison told me that Citigroup was offering this opportunity first to me, as one the Private Bank's most important clients, to ensure that I have an opportunity to subscribe. Ms. Davison also MA inatmence, that 1 was virtually assured of receiving an 18- 20% return on my investment, with a-possible return of as much as 30%. She further emphasized that Citi "really did their due diligence" on this deal and was anticipating putting its 0 ey in as an investor. Finally, Ms. Davison made affirmative assurances regarding regarding ' to protect my interest in the investment; she advised that I should not worry because Ciii was going to remain actively "involved in the deal," including possibly as an investor.
• :Nil
. • .
12. In light of Ms. Davison's statements regarding the exceptional merits of the AIG Investment, and particularly the fact that Citibank was anticipating making its own investment in the deal, I inquired whether Citibank was confident enough in the assurances Ms. Davison had made to me to loan me the necessary funds for the MG Investment. After further dismission between me, Ms. Davison and other representatives of FTCI, Citibank offered to loan mo \$10 million on the express condition that the loan be used exclusively to fund FTClis inv the MG Investment.
01. I did not need to borrow the money for FTC to make the Atainvestnient However, Citibank offered the loan at an interest rate substantially Iower the rate of the return that Ms. Davison assured would result from the MG Investment. Moreover, Citibank promised to loan me the funds for the life of the AIG Investrnent.I Consequently, on the basis of Ms. Davison's assurances, I understood Citigroup to,f, offering me, as one of the Private Bank's most important clients, the opportunity to Money to fund an investment by FTCI in a transaction that was assured of yielding a substantial net positive return, was backed by Citibank's extensive due diligence would be protected by the continued involvement of Citibank, which was anticipating making an investment in the deal. Under the circumstances, I could not refuse such an offer.
I4. At some point prior to August of 1999, I was provided with a so-called "Pitch Book" promoting the AIG Investment. I am certain that such materials did not contain any information that even remotely suggested to me that 1 had any reason to doubt Ms. Davison's aces, or raise any concern that my long-standing bankers, and now advisors, were not
I The loan was originally struettued as a l0-year loan in order to be cecerminous wan the MG 11We:it:Mali However, Ms. Davtson asked me if I -would not mind" structuring the loan as a short-tam Lean because, she said. shod-term loans are accounted for mare favorably on the bank's books than long term loans. She assured me that
acting in my or FTCPs brat interests in recommending this investment. To the contrary, 1 was persuaded by Ms. Davison's assurances that the Private Bank would be "involved" in the deal, including potentially as an investor.
15. Based upon all of the foregoing, I decided to proceed with the transaction that I had discussed with Ms. Davison, and on or about August 2, \[999,1 executed a promissory note in the face amount of \$10 million in favor of Citibank (the "1999 Note"), and then, Private Bank's knowledge and approval, and, as required by Citibank, the loan pr wired by Citibank to my Citibank account, and then transferred to FTCI's Citibank account, and then transferred to the bank account designated by Citibank for making the AIG Investment.
01. At some point, ! also received an Offering Circuls4sscribing the AIO Investment. Based upon what I recall receiving I understood that investors such as PI-C1 would have the right to change the manager of the fund -- 0 -- by vote of a certain percentage of A,k, the investment or note holden.
?C\\ - 17. This fact was very important to me since it represented the most significant way in which PTO's interest in the Al srilly could be protected in the event that the fund ...A. ) manager was not pursuing a favorable successful investment strategy. In fact, I believed, based upon Ms. Davison's assurance that the Private Bank was going to be "involved," coupled with the fact that I understood that Citibank's affiliate — Salomon Barney -- was acting as Placement Agent, that, if there was ever a problem with the fund's management, in order to protect the collective interests of FTC!, Citigroup's other important clients and the Private Bank, itself, the Private Bank would have the ability to either influence the fund manager appropriately or amass the consent of the necessary interests in the fund to promptly replace the fund manager.
the maturity date of die loan would be extended annually, so that neither t. nor FTC, would over have to come out of pocket in connection whh this invutawat.
18. During 2000, Ms. Davison spoke tame about another, similar investment fund, this one to be managed by MassMutual (the "Maashdutual Fund"). I understood, based upon my prior discussions with Ms. Davison in 1999, that there would be additional investment opportunities similar to the AIG investment, and 1 further understood the MassMutual Fund to be such an opportunity. There were negotiations between my ICI.), ,oentatives and legal advisors, including while they and I were in the U.S. Virgin Islands, and Ms. Davison and other representatives of Citigroup, including, but not limited to the Private Bank, cone MassMutual Fund. Ultimately, and based upon discussions substantially similar to occurred in 1999,1 borrowed another \$10 million from Citibank, which funds were expressly required to be contemporaneously used by me to fund FTCI's investment in the MassMutual Fund, Again, I signed a promissory note payable to Citibank Oyote"), and the underlying funds were transferred from Citibank to ray tint, to FTCI's acnount, and then to the account designated by Citibank for the ine rt in the MassMutual Fund.
01. By the Spring of 2001, we made a shocking discovery. Largely through the review of monthly statements furnished by AIG, we discovered that the MG investment was suddenly and rapidly deteriorating, at adine when the similarly-structured MassMutual Fund appeared to be performing as expected. These inconsistent results suggested to me that the problems resided with the manager of the AIG investment, as opposed to prevailing market conditions,2 and that My bankers and advisors at the Private Bank were not monitoring the progress of this fund Ms. Davison assured me they would.
\_\_\_\2Inote that FTCI's investment in the MassMutual Fund now also has drastically declined in value.
share our concerns, find out what was transpiring with the AIG Invmunem and to request that the Private Bank take action, including coordinating the replacement of the fund manager.
21. I understand that Ms. Davison initially indicated to FTCI's representatives that she would cooperate with FTC! in pursuing the removal of AIG as manager. However, l subsequently learned the horrifying truth of Citibank's betrayal. 1 was informed that not only was Ms. Davison unable to timely provide FTC1 with the information we needed to pursue a change of managers, but that Citigroup/Citibank was unwilling to assist us at all since to do so would jeopardize an apparently more lucrative relationship that Citibank's affiliate, SSB, had with AIG.
01. Citibank's inability and, ultimately, unwillingness FTC! in pursuing its rights in order to protect its interests, delayed FTCI from e e yursoing its rights to change the manager of the AIG Investment, until such time th(changing the manager would have been futile since the investment rapidly detcriomted(Knear zero.
01. Prior to 2001,1 had every to believe that the assurances on which I had based my decision to borrow the inv s from Citibank and cause FTC} to subscribe for the AIG Investment were or to that time, I was never was informed by Ms. Davison or anyone else at Citigrou libank, and never learned through my review of any of the materials providedAts me, that Citigroup or Citibank or the Private Bank would in any way be unable or unwilling to assist me or FTC in pursuing our rights with respect to the MG Investmen km Nor did I ever learn prior to 2001 that SSB had an investment banking relationship sis\_ with AIO, uch less a relationship that my bankers and advisors would hold in higher regard Y. than my long-standing relationship with the Private Bank.
•
24. Had I known of these conflicts end the fact that the Private Bank's advice and recommendation was unpaired and tainted in such a meaningful way, or that Ms. Davison's assurances that Citibank would be "involved" in the deal were untrue in any way, I never would have proceeded with either the AIG Investment or the MassMutual Fund, never would have executed either the 1999 Note or the 2000 Note, and never would have caused FTCI to invest 620 million in the investments that were being "placed" by SSB.
01. I now understand that FTCI's interest in the MG Investment is neargolthlact, and further that FTCI's interest in the MassMutual Fund has drastically decreased in value.
Li
26. For the foregoing reasons, and those set forth in the accompanying memorandum of law and other submissions made on my and FTCI's behalf, I respectfully request that the Court deny Citibank's motion in its entirety.
Executed this \_\_ day of October, 2002
Jeffrey E. Epstein
Rothstein Rosenfeldt Adler\
Attorneys at Law
[REDACTED] s. [REDACTED]\
Direct Dial: 954-315-7266\
bedwards@rra-law.com
July 22, 2009
**Via Facsimile:**
305-931-0877 Adam D. Horowitz, Esquire\
Stuart S. Mernelstein, Esquire\
561-832-7137 Isidro Manuel [REDACTED], Esquire\
305-931-0877 Jeffrey Marc Herman, Esquire\
305-358-2382 Katherine Earthen Ezell, Esquire\
Robert C. Josefsberg, Esquire\
561-684-5707 Jack [REDACTED], Esquire
Dear Counsel,
We have recently received Notice for Depositions from Adam Horowitz for several witnesses and the lever from Jack [REDACTED] indicating an intent to take others. We intend to Cross-Notice each deposition. Additionally, we intend to set the following other individuals for video deposition:
1. 1. Donald Trump (West Palm Beach)
1. 2. Glen [REDACTED] (West Palm Beach)
1. 3. Ghislain Maxwell (New York)
1. 4. Sara [REDACTED] (New York)
1. 5. Leslie Wexner (Ohio)
1. 6. Bill Clinton (D.C.)
1. 7. Paula-Heil.-(New York)
1. 8. Jean-Luc Bruhel (New York)
| Δ π EXHIBIT 3 | |
| ------------------------------------ | --- |
| Deponent [Signature] | |
| Date 2/31/09 Rptr. O-1 | |
| DEPOSITOR | |
We will choose dates that have not already been occupied by other depositions already set in this case. If you would like to be included in the scheduling of these depositions, please provide me with your scheduling secretaries' names and e-mail addresses. If any of you do ilot need to be consulted regarding the scheduling of these depositions, please advise me of that as wells.
Very truly yours,
ROTHSTEIN ROSENFELDT ADLER CO 'S J. Esquire iS )3JE/rngl ) 49
Partner
Fort the Firm
#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
JANE DOE NO. 2,
Plaintiff
vs.
JEFFREY EPSTEIN,
Defendant
C.
JANE DOE NO. 3, CASE NO: 08-CV-80232-MARRA
Plaintiff
CASE NO: 08-CV-80119-MARRA/
vs.
AILS'
JEFFREY EPSTEIN,
Defendant
L 11
JANE DOE NO. 4, CASE NO: 08-CV-80380-MARRA/JOHNSON
CASE NO: 08-CV-80119-MARRA
JANE DOE NO. 5, CASE NO: 013•CV-80381-MARRA
Plaintiff
vs.
JEFFREY EPSTEIN,
Defendant
CO
JANE DOE NO. 6. CASE NO: 08-CV4-MAIII
Plaintiff
vs.
JEFFREY EPSTEIN,
Defendant
JANE DOE NO. 7,
Plaintiff '1 1410"
JEFF 4. IN,
ndant
CASE NO: 08-CV-80993-MARRA/JOHNSON
CASE NO: 08-CV-80119-MARRA/J
CASE NO: 08-CV-80811-MARRAIJOHNSON
C.M.A.,
Plaintiff
vs.
JEFFREY EPSTEIN,
Defendant
JANE DOE, CASE NO. 08-CV-O8
Plaintiff,
Vs.
JEFFREY EPSTEIN, et al.
Defendant.
DOE II, CASE NO: 09-CV-80469-MARRA/JOHNSON
vs.
Plaintiff '1 11114fiy
) JEFFREY EPSTEIN, et al.
Defendants.
JANE DOE NO. 101,
Plaintiff
vs.
JEFFREY EPSTEIN,
Defendant
CASE NO: 08-CV-80119-PAARRN
CASE NO: 09-CV-80591-MARRAI
JANE DOE NO. 102, CASE NO: 09-CV-8085 14/ 41,RA/JOHNSON
vs.
"S C)
Plaintiff
JEFFREY EPSTEIN,
Defendant
#### PLAINTIFF, JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A \$15 MILLION BOND. TO SECURE POTENTIAL JUDGMENT
COMES NOW Plaintiff Jane Doe, by and through undersigned counsel, and hereby files this Motion for Injunction, pursuant to Federal Rule of Civil Procedure 64, for appointment of a receiver to take charge of Epstein's property, and to post a \$15 million bond to secure any potential judgment in this case, for the reasons explained in the accompanying supporting memorandum.
Plaintiff Jane Doe, by and through her undersigned counsel, files this memorandum In support of her motion for appointment of a receiver to take charge of
#### CASE NO: 08-CV-80119-MARRA/JOHNSON
Epstein's property and to post a \$15 million bond to secure any potential judgment in this case.
Epstein Is a billionaire who recently has been fraudulently transferring his assets overseas and elsewhere with the intent to prevent Jane Doe (and possibly numerous other victims of his sexual abuse) from satisfying any judgment they might obtain against him. Federal Rule of Civil Procedure 64 guarantees Jane Doe all available state law pre-judgment remedies to respond to these fraudulent transfers. Florida has adopted the Florida Uniform Fraudulent Transfer Act (FUFTA), Fla. Stat. Ann. § 726,101 et seq., which gives the Court power to appoint a receiver to take charge of assets that are being fraudulently transferred. Given the serious allegations of sexual abuse against Jane Doe when she was a minor, this Court should appoint a receiver to control and account for Epstein's assets and direct the receiver to post a \$15 million bond with this Court on behalf of Epstein to satisfy t judgment that Jane Doe might obtain.
### STATEMENT OF MATERIAL FACTS
1. Defendant Jeffrey Epstein is the defendant in this action, which involves claims by Jane Doe that Epstein repeatedly sexually abused her when she was a minor. Because of the egregious and repeated acts of sexual abuse committed by Epstein, her complaint seeks damages in excess of \$50 million, including punitive damages. See Amended Complaint, ¶ 2.
1. Defendant Jeffrey Epstein is extremely wealthy. According to reputable press reports in the New York Times and elsewhere, he is a billionaire. He is also the owner
CASE NO: 08-CV430119-MARRa of a Caribbean island in the Virgin Islands (Lithe St. James Island), where he serves as a financial advisor to other billionaires. He was previously a financial trader at Bear Steams. It is therefore reasonable to infer that he has a great deal of financial sophistication. See Affidavit of Paul Cassell at ¶ 2 Attachment A to this Pleading.
3. According to reputable press reports, before his recent incarceration (discussed below), he frequently traveled around the globe in the company of such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he has international contacts, Including international financial contacts. See Affidavit of Paul Cassell at ¶ 3.
1. Over the past year, approximately 25 civil suits have been filed in Florida state courts and Florida federal courts raising similar allegations of sexual abuse by Jeffrey Epstein against minor girls. These complaints seek damages comparable to those sought by Jane Doe in this case. See Affidavit of Paul Cassell at ¶ 4. Accordingly, Epstein has currently pending against him lawsuits seeking more than \$1 billion in damages. He thus faces financial ruin. Id.
1. On June 30, 2008. Jeffrey Epstein pled guilty to one count of procuring a person under 18 for prostitution and one count of felony solicitation to prostitution before the Circuit Court of the Fifteenth Judicial circuit in and for Palm Beach County, Florida. He was sentenced to 18 months in jail.
1. Since those guilty pleas, he has been incarcerated in the Palm Beach County Detention facility. However, he has also been allowed out on a 'work release" program, where he works at managing his financial interests. Affidavit of Paul Cassell at ¶ 5.
CASE NO: 08-CV-80119-MARRAMM
7. Given the substantial claims against him, his International connections, and other information, Jane Doe's counsel has been gravely concerned that Epstein will fraudulently transfer all of his assets to overseas locations to defeat collection of any judgment that she might obtain against him. Accordingly, as part of discovery in this case, Jane Doe propounded requests for admissions by Epstein regarding whether he was fraudulently transferring assets. Rather than answering these requests for admission about on-going fraudulent transfers of his property, Jeffrey Epstein asserted his Fifth Amendment right against self-incrimination. Affidavit of Paul Cassell at 116.
1. Jeffrey Epstein's net worth is greater than \$1 billion. Jane Doe's First Request for Admissions (RFA's) #5, Attachment B to this Pleading; Epstein's Resp. to RFA's #5, Attachment C to this Pleading.
1. Since he was incarcerated, Jeffrey Epstein has, directly or indirectly (through the services or assistance of other persons) conveyed money and assets in an attempt to insulate and protect his money and assets from being captures in civil lawsuits filed against him. Epstein's Resp, to RFAs #6.
1. Epstein owns and controls real estate property in foreign countries, including the Caribbean. Epstein's Resp. to RFAs #7 and #8.
1. Epstein is currently moving significant financial assets overseas, outside of the direct territorial reach of federal and Florida courts. Epstein's Resp. to RFA #21.
1. Epstein is transferring these assets with the intent to defeat any judgment that might be entered against him in this and other similar cases. Epstein's Resp. to RFA #22.
CASE NO: 00-CV-S0119-MARRal
13. Epstein could currently post a \$15 million bond to satisfy a judgment in this case without financial or other difficulty. Epstein's Resp. to RFA #23.
01. Epstein has blocked all discovery, In this and other related cases, regarding his assets. Affidavit of Paul Cassell at ¶¶ 7, 8.
### ARGUMENT
# I. EPSTEIN IS FRAUDULENTLY TRANSFERRING HIS ASSETS.
As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his assets. In particular, he is currently moving significant financial assets overseas, outside of the direct territorial reach of Federal and Florida courts, and is doing so with the specific intent to defeat any judgment that might be entered against him In this and other similar cases. Statement of Material Facts #11 and #12.
Because these material facts rest, in part, on Epstein's invocation of his Fifth Amendment privilege against self-incrimination, it is pertinent to note that Jane Doe is entitled to an adverse inference from his invocation of his Fifth Amendment rights when asked whether he was fraudulently transferring his assets overseas. Jane Doe propounded requests for admission to Epstein that asked specifically about on-going fraudulent transfers of assets. In response, Epstein asserted his Fifth Amendment right to refuse to answer incriminating questions. Of course, Epstein's "invocation of his Fifth Amendment privilege, like the assertion of any privilege, stands In stark opposition to the otherwise liberal discovery rules, and 'undermine[s] to some degree the trial system's capacity to ascertain the truth.'" United States ex rel. DRC, Inc. v. Custer Battles, LLC, 415 F.Supp.2d 628, 632 (E.D. Va. 2006) (quoting Robert HeIdt, The
CASE NO: 08-CV-80119-NIARFtA/JOHNSON Conjurer's Circle — The Fifth Amendment Privilege in Civil Cases, 91 YALE L.J. 1062, 1082 (1982)). As a result, where a witness refuses to testify in a civil case on Fifth Amendment grounds, the permissible inference is that the witness's testimony, had it been given, "would not have been favorable to the claim." United States v. A Single Family Residence, 803 F.2d 625, 629 n.4 (11th Cir. 1986). Of course, the Fifth Amendment is not violated by such an inference. The concerns animating the Fifth Amendment right against self-incrimination are not in play "pin a civil suit involving only private parties" because no party brings to the battle the awesome powers of the government, and therefore to permit an adverse inference to be drawn from exercise of the privilege does not implicate the policy considerations underlying the privilege: Baxter v. Palmigiano, 425 U.S.308, 335 (1976). An adverse inference is entirely justified in this case. Epstein has remained silent when asked such straightforward requests for admissions: • Since being Incarcerated you have, directly or indirectly (through the services or assistance of other persons), conveyed money or assets in an attempt to insulate or protect your money or assets from being captured in ?S civil e lawsuits filed against you. RFA's #6. re moving significant financial assets overseas, outside of the direct + territorial reach of the U.S. and Florida Courts. RFA's #21. • You are making asset transfers with the intent to defeat any judgment that might be entered against you in this or similar cases. RFA's #22.
#### CASE NO: 08-CV-80119-MARRAJJOHNSON
The silence in the face of these questions speaks far louder than words. As Justice Brandeis recognized long ago, sisJilence is often evidence of the most persuasive character.'" Baxter v. Palmigiano, 425 U.S. 308, 319 (1976) (quoting U.S. ex ml. Bilokumsky v. Tod, 263 U.S. 149, 153-54 (1923)). This is plainly one of those situations.
In a civil case, drawing an adverse inference is the proper action for a court to take when a litigant blocks legitimate discovery through exercise of a Fifth Amendment invocation. "(WThile there is no doubt that a witness is entitled to assert the privilege in a civil case, it is also dear that an adverse inference based on a refusal to answer In a civil case is an appropriate remedy, as it provides some relief for the civil litigant whose case Is unfairly prejudiced by a witness' assertion of the Fifth Amendment privilege without placing the witness in the 'cruel trilemma' of choosing among incrimination, perjury, or contempt? United States ex rel. DRC, Inc. v. Custer Battles, LW, 415 F.Supp.2d 628, 633 (E.D. Va. 2008). The Eleventh Circuit has not hesitated to support district courts that draw an adverse inference from silence. For example, in United States v. Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996), the district court drew an adverse inference when claimants to real property refused to answer questions regarding the property. The Eleventh Circuit affirmed that decision, explaining that "(tihis Court has held . . . that the trier of fact may take an adverse inference against parties to a civil action refusing to testify on Fifth Amendment grounds. id. at 1129 (citing United States v. A Single Family Residence, 803 F.2d 625, 629 n.4 (11th Cir. 1986)). Similarly, in Arango v. U.S. Dept. of the Treasury, 115 F.3d 922, 926 (11th Cir. 1997), the Eleventh Circuit explained that 'The First Amendment
#### CASE NO: 08-CV-80119-MARRAJJOHNSON
does not forbid adverse inferences against civil litigants . . . who assert the privilege against self-incrimination."
Here an adverse inference is entirely appropriate. In addition to Epstein's refusal to answer questions, there are strong circumstantial reasons for believing he is hiding his assets. As explained above, see Statement of Material Facts #1 through #3, Epstein clearly has the means to hide his assets — he is a sophisticated financial advisor. And given that the sexual abuse lawsuits brought against Epstein threaten him with financial ruin — he has a clear motive for hiding his substantial assets. Finally, Epstein is currently on work release, running his financial affairs from his office — giving him the dear opportunity to make the necessary arrangements to move his assets to overseas or other unreachable locations. Thus, there is a "perfect circumstantial evidence case that (Epstein) hats\] means, motive, and opportunity" to fraudulently transfer assets. See United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001) (finding probable cause for an arrest based solely on a showing of means, motive, and opportunity). The fact that this evidence is circumstantial rather than direct proof of the transfers is irrelevant, because 'circumstantial evidence is not less probative than direct evidence, and, in some cases is even more reliable.'" United States v. Ranum, 96 F.3d 1020, 1028 (7th Cir. 1996) (quoting United States v. Hatchett, 31 F.3d 1411, 1421 (7th Cir. 1994)).
For all these reasons, the Court should conclude that Epstein is fraudulently transferring assets.
CASE NO: 08-CV-80119-MARRa
#### II. JANE DOE IS ENTITELD TO THE PROTECTIONS OF THE UNIFORM FRAUDULENT TRANSFER ACT AS ADOPTED BY FLORIDA
in light of Epstein's fraudulent asset transfers, Jane Doe is entitled to prejudgment remedies to protect her against Epstein's efforts to block her from satisfying the judgment she is likely to ultimately obtain in this case. Federal Rule of Civil Procedure 64 guarantees Jane Doe during the course of this suit "all remedies providing for seizure of person or properly for the purpose of securing satisfaction of the Judgment ultimately to be entered in the action" that are "available under the circumstances and in the manner provided by the law of the state in which the court is held? The Rule goes on to provide that "(tMho remedies thus available include arrest, attachment, garnishment, replevin, sequestration, and other corresponding or equivalent remedies, however designated and regardless of whether by state procedure the remedy is ancillary to an action or must be obtained by en independent action." This "long-settled federal law providles) that in all cases in federal court, . state law is incorporated to determine the availability of prejudgment remedies for the seizure of person or property to secure satisfaction of the judgment ultimately entered." v. Cascade Intern., Inc.. 21 F.3d 1520, 1531 (11th Cir. 1994). Accordingly, under this Rule, this Court looks to Florida law to determine Jane Doe's rights to pre-judgment relief.
To prevent fraudulent transfers of assets before judgment, Florida has adopted the Uniform Fraudulent Transfer Act. Fla. Stat. Ann. § 726.101 et seq. Under the Florida's Uniform Transfer Act (FUFTA), courts are broadly empowered to take action to block certain "fraudulent transfers' of assets. Jane Doe is accordingly entitled to invoke the remedies under this Act if Epstein is making -fraudulent transfers" of his assets.
CASE NO: 013-CV-80119-MARFta
The Act defines a 'fraudulent" transfer of assets as one made lwlith actual intent to hinder, delay, or defraud any creditor of the debtor.' Fla. Stat. Ann. § 726.105(1Xa). The FUFTA also contains a "quite broad' definition of °transfer." Nationsbank, N.A. v. Coastal Utilities, Inc., 814 So.2d 1227, 1230 (Fla. Ct. Apps. 2002). It extends to 'every mode, direct or indict, absolute or conditional, voluntary or involuntary, of disposing of or parting with an asset or an interest in an asset, and includes payment of money, release, lease, and creation of a lien or other encumbrance.' Ra. Stat. Ann. § 726.102(12). This "broad definition includes 'every mode of disposing of an asset and does not limit the statute to direct transactions made by the debtor hinVherself.' Nationsbank, N.A. v. Coastal Utilities, Inc., 814 So.2d 1230. As noted above, Epstein Is transferring his assets with the intent to defeat any judgment that might be entered against him in this and other similar cases, see Statement of Material Facts #12, and therefore is plainly covered by the Act.
The FUFTA extends is protections to "creditors' — such as Jane Doe, who is a "creditor of Epstein's within the meaning of the Act. The FUFTA extends its protections not merely to judgment creditors, but more widely to future creditors who have a 'claim," including a "claim" that has not yet been reduced to judgment. See Fla. Stat. Ann. § 726.102(2) (defining a claim as a "right to payment, whether or not the right is reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured, or unsecured."); Fla. Stat. Ann. § (defining creditor protected by the act as "a person who has a claim"). See generally Freeman v. First Union Nat Bank, 865 So.2d 1272, 1277 (Fla. 2004) (noting that the definition of CASE NO: 08-CV-80119-MAFtRA/
claim is 'broadly constructed" under the FUFTA). This means that "as is universally accepted, as well as settled in Florida, a 'claim' under the Act may be maintained even though contingent and not yet reduced to judgment? Freeman, 865 at 1277 (internal quotations omitted). In Florida, then, "'tort claimants are as fully protected against fraudulent transfers as holders of absolute claims.- Id. at 1277 (quoting Money v. Powell, 139 So.2d 702, 703 (Fla. Ct. Apps. 1962). Jane Doe is, e, a tort claimant against Epstein.
( 14/ For all these reasons, Jane is entitled to the full protections of the Florida Uniform Fraudulent Transfer Act.
#### 1 14/:\\ ) III. UNDER THE UNIFORM FRAUDULENT TRANSFER ACT, JANE DOE IS ENTITLED TO THE REMEDIES OF APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF EPSTEIN'S ASSETS, FILE AN ACCOUNTING OF THOSE ASSETS WITH THE COURT, AND TO POST A \$15 MILLION BOND
Under the Uniform Fraudulent Transfer Act, this Court is given broad powers to prevent fraudulent transfercf;seets. The remedies provided by the Act specifically include:
- 1. An injunctio aa further disposition by the debtor . of the asset transferred . . ..:
- 2. Appointment of a receiver to take charge of the asset transferred or of other property of the transferee; or
- 3. Any other relief the circumstances may require. Fla. Stet Ann. § 726.108(c).
### CASE NO: 08-CV-80119-MARRAMOHNSON
Jane Doe seeks one of these specifically provided remedies — namely, appointment of a receiver to take charge of Epstein's assets. Appointment of a receiver will serve three important goals: first, if a receiver has control of Epstein's assets, Epstein's ability to further transfer those assets will be blocked; second, the receiver can provide an accounting of Epstein's assets, allowing Jane Doe (and the Cost) to take whatever other action may be appropriate; and, third, the receiver can post a bond of \$15 million with the Court so that Jane Doe will have funds to satisfy any judgment that she might obtain.
The Court should appoint a receiver to account for Epstein's assets. The appointment of a receiver is directly authorized by the FUFTA. Fla. Stat. Ann. § 726.108(c); see Freeman v. First Union Nat. Bank, 865 So.2d 1272, 1277 (Fla. 2004) (noting that appointment of a receiver is remedy provided by the FUFTA). A receiver is the only way to start to block further dissipation of assets — by, first, gaining control over Epstein's assets and then, second, making an accounting of what assets of Epstein's remain in this country or are otherwise subject to control by this Court. Given Epstein's Fifth Amendment invocations and other obstructions regarding any discovery concerning his assets, see Statement of Material Facts #14, it is currently impossible for Jane Doe to protect her interests in blocking Epstein's fraudulent transfers. Indeed, one of the other remedies specifically specified in the Act — "[a]n injunction against further disposition by the debtor . of the asset transferred" — is presumably unworkable given that there is no way to know what assets Epstein possesses, much less where he is transferring them to. Cf. Special Purpose Accounts Receivable Co-op Corp. v. Prime One Capital Co., L.L.C., 2007 WL 4482611 (S.D. Fla. 2007) (Marra, J.) (refusing to
CASE NO: 08-CV-80119-MARFta apply any heightened pleading requirements to UFTA claims a\[gliven this lack of access to information on the part of a plaintiff in a fraudulent transfer case?). Jane Doe therefore needs a receiver to account for Epstein's assets to the Court.
The receiver should make a report to the Court regarding Epstein's assets so that Jane Doe can determine what additional further action is required. For example, Jane Doe might need to take action to set aside various transfers. But even now, it is clear that the receiver should take one additional step: Once a receiver is appointed and accounts for Epstein's assets, the receiver should post a \$15 mdlion bond on behalf of Epstein with the Clerk of the Court in order to satisfy any judgment that Jane Doe might obtain in this case.
A \$15 million bond is reasonable. F" \\ n pstein's tremendous net worth, he can post a \$15 million bond without any financial or other difficulty. See Statement of Material Facts #13. Second, given the egregious acts of sexual abuse Epstein committed against Jane Doe (who was a minor at the time) — and the punitive damages claim present in this case —\$15 million is a reasonable bond amount given the nature of the judgment that Jane Doe is likely to obtain at trial. Jane Doe seeks more than \$50 million damages. See First Amended Complaint, ¶ 1. Her complaint alleges that Jeffrey Epstein had a sexual obsession for minor girls. Id. at ¶ 10. To satisfy that obsession, Epstein engaged in an elaborate scheme whereby his assistants recruited minor girls for the purpose of engaging in prostitution. Id. at ¶ 11. Her complaint explains that:
Beginning in approximately February 2003 and continuing until approximately June 2005, the defendant coerced and enticed the impressionable, vulnerable, and economically deprived then minor \[Jane
### CASE NO: 08-CV-80119-MARFtAl
der to commit various acts of sexual misconduct against her. s included, but were not limited to, fondling and inappropriate sexual touching of the then minor [Jane Doe], sexual A and masturbation of Defendant, Jeffrey Epstein, in the of the then minor Plaintiff, and encouraging and coercing the • Plaintiff to become involved in prostitution.
Doe finally notes that in June 2009, Epstein entered pleas of 'guilty to tate crimes involving the solicitation of minors for prostitution and the iinors for the purposes of prostitution, for which Defendant Epstein was months incarceration in Palm Beach County jail to be followed by 12 ity control (house arrest). Id. at 1122.
a has propounded various discovery requests regarding these\\e 3ffrey Epstein. It is noteworthy that Epstein has asserted a Fifth, •incriminatIon privilege to these requests, rather than provide answers.
ne Doe has asked Epstein to admit that he committed sexual assault xa when she was minor. Plaintiffs First Request for Admissions to in 11. In response, Epstein asserted his Fifth Amendment privilege not nself.
se reasons, directing the receiver to post a \$15 million bond on behalf lonable under the circumstances.
\\ "also grants the court equity powers to remedy . . . fraud." Invo ;omerset Venturer, Inc., 751 So.2d 1263, 1267 (Fla. Ct. Apps. 2000). >visions are "supplement[ed]" by i\`the principles of law and equity.' Fla. 3.111. It is well-settled that "[a]it equitable action requires equitable Tyler, 890 So.2d 246, 251 (Fla. 2004), and "equity will do what ought to
Doe) in o These ad and Meg: miscondui presence then mind
Id. at ¶ 18. Jane
various Florida s procurement of r sentenced to 18 months commun
Jane Do. allegations to J4 Amendment self For example, Ja against Jane Dc Defendant Epste to incriminate hir
For all the of Epstein is rea:
The UFT, Florida, Inc. v. The FUFTA's pn Stat. Ann. § 72 relief." Prince v.
CASE NO: 08-CV-80119-MARRA/JOHNSON be done." Sterling v. Brevard County, 776 So.2d 281, 284 (Fla. Ct. Apps. 2000). The Court should therefore also exercise its equitable powers to impose the same remedies that Jane Doe requests.
Of course, in equity, the Court considers the relative positions of the two claimants. Here, Jane Doe has presented substantial claims of sexual abuse against her while a minor, while Epstein (who pled guilty to felony charges involving such conduct) has taken the Fifth Amendment rather than answer questions about his sexual abuse of Jane Doe. If Jane Doe does not obtain the remedy that she is requesting, then Epstein may well be able to move all of his assets to unreachable locations, leaving her with a substantial tort claim and no possible'way to satisfy it. On the other hand, appointing a receiver will not interfere with any legitimate interest of Epstein, particularly given his phenomenal wealth.
When this Court proceeds in equity, it 'will not suffer a wrong to be without a remedy? Connell v. Mittendod, 147 So.2d 169, 172 (Fla. Ct. Apps. 1962). This case cries out for the Court to intercede and take action to avoid allowing a confessed and wealthy sex offender from concealing his assets and depriving his victims — including Jane Doe — from satisfying any judgment that they may well obtain against him. A receiver with control over Epstein's assets is a modest and entirely appropriate step to take given Epstein's actions.
For the consideration of the Court, a proposed order adopting these remedies is attached to this pleading.
#### CASE NO: 08-CV-80119-MARRA/JOHNSON CONCLUSION
WHEREFORE, in view of the fraudulent transfers being made by Jeffrey Epstein to prevent Jane Doe from satisfying any judgment she might obtain in this case, the Court should appoint a receiver to take charge of Epstein's property and direct the receiver to provide the Court with an accounting of Epstein's assets and post a \$15 million bond to secure any potential judgment that Jane Doe might o se.
DATED this 19th day of June, 2009.
+6s
Respectfully'Submitted,
Brad .
\\ ROTHSTEIN R NFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Telephone (954) 522-3456 Facsimile (954) 527-8663 Florida Bar No.: 542075 E-mail: bedwardserra-law.com
A Bradley J.
And
Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: casselloalaw.utah.edu
### CASE NO: 08-CV-80119-MARRAIJOHNSON CERTIFICATE OF SERVICE
CERTIFY that on June 19, 2009, I electronically filed the foregoing e Clerk of the Court using CWECF. I also certify that the foregoing g served this day on all parties on the attached Service List in the, either via transmission of Notices of Electronic Filing generated by le other authorized manner for those parties who are not authorized to
ally filed Notices of Electronic Filing. C O Ma -- < 29
I HEREB
document with t document is bei manner specifies CM/ECF or in soi receive electronic
CASE NO: 08-CV-80119-MARRA/ [REDACTED]
**SERVICE LIST**\
**Jane Doe v. Jeffrey Epstein**\
**United States District Court, Southern District of Florida**
Jack Alan Goldberger, Esq.\
[Jgoldberger@acwpa.com](mailto:Jgoldberger@acwpa.com)
Robert D. Critton, Esq.\
[rcritton@bclclaw.com](mailto:rcritton@bclclaw.com)
Isidro Manual [REDACTED]\
[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net)
Jack [REDACTED]\
[iph@searcylaw.com](mailto:iph@searcylaw.com)
Katherine Warthen Ezell\
[KEzell@podhurst.com](mailto:KEzell@podhurst.com)
Michael James Pike\
[MPike@bclclaw.com](mailto:MPike@bclclaw.com)
Paul G. Cassell\
[cassellp@bclclaw.com](mailto:cassellp@bclclaw.com)
Richard Horace Willits\
[lawyerswillits@aol.com](mailto:lawyerswillits@aol.com)
Robert C. Josefsberg\
[riosefsberg@podhurst.com](mailto:riosefsberg@podhurst.com)
Adam D. Horowitz\
[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com)
Stuart S. Mermelstein\
[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com)
William J. Berger\
[wberger@rra-law.com](mailto:wberger@rra-law.com)
# AFFIDAVIT OF PAUL G. CASSELL. ESOUIRE
ait sc
1. I, Paul Cassell, have person knowledge of the matters set forth herein. I attorney licensed to practice in the State of Utah since 1992. My office is I at the University of Utah College of Law, where I am a law professor. CO .1 with other attorneys, I represent plaintiff Jane Doe in this matter.
1. It appears that defendant Jeffrey Epstein is an extremely wealthy\\ ACI ,) 4 )- lual. According to reputable press reports, his net worth is in the hundreds ions of dollars — if not, indeed, a billion dollars. See, e.g., New York Time, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of ig billionaires became a billionaire himself, left his estate on Little St. James with its staff of 70 and its flamingo-stocked lagoon, boarded a private ,ter and flew to Florida. There turned himself in at the Palm Beach y jail and began serving4 Wikipedia entry about e y Epstein, he is a billionaire and owner of a island in the Virgin Island (Little St. James Island), and was a financial at Bear Steams. He then founded his own financial management firm, J. for soliciting prostitution."). According
am an locate( Along
indivic of mill July 1, advisix Island, helicol Count•. to the private trader
ailed Financial Trust Co., located on his private island in He reportedly only took billionaire clients. •
ys and I have made repeated efforts to find published idant Jeffrey Epstein in general and his financial dealings in :tailed published source of information about defendant tve been able to locate is an article that was published in lard. Vicky is a contributing editor to Vanity Fair, a nd a weekly columnist for the London Evening Standard. in the intemet at
,ordpress/archives/30.\\
the Vanity Fair article, defendant Jeffrey Ep ie financial assets of other billionaires. .He repo ly use whose net worth was more than \$1 billion. Unlike other T, Epstein kept all his deals and clients secret (with one Leslie Wexner — who ,Epstein claims was his mentor). He ig in international currency markets, which helped him f and his clients. As a result, it is reasonable to infer that he Epstein and Col, later c the U.S. Virgin Island.
# 3. Other attome
AS 4knf' , ormation about defer particular. The most de Jeffrey Epstein that I ha Vanity Fair by Vicky V contributor to CNBC, a The article can be fount htto://vickyward.com/v.
# 4. According to •
wealthy by managing tf limited his clients to the fund managers, howeve exception — billionaire has great skills in tra.dir make money for himsel