EFTA00723522

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA S CASE NO: Plaintiff, 50200SCA037319XXXXMB AB vs. JEFFREY EPSTEIN, Defendant. I PLAINTIFF'S RESPONSE TO EPSTEIN'S MOTION FOR SANCTIONS AND TO IDENTIFY Plaintiff, M. files this Response to Epstein's Motion for Sanctions and to Identify. introduction Apparently Epstein and his counsel do not have a problem with press, they just have a problem with bad press. To put the quotes cited by defense in their motion in context, the court must also see some of the numerous quotes given by Epstein's defense team. "These women are liars. We've established that " "It was just a childish performance by the Palm Beach Police Department " - Any. Jack Goldberger, August 8, 2006, Palm Beach Post. (Ex. I). "There was never any victims." (sic) - Any. Jack Goldberger, July 23, 2009, Palm Beach Post. (Ex. 2). EFTA00723522 "...because the craziness of this police chief we have the charge ofsolicitation." - Atty. Gerald Lefcourti, July 27, 2006, New York Post (Ex. 3). "He never denied girls came to the house," Goldberger said. But when Epstein was given a polygraph test, "he passed on knowledge of age," the attorney said. - Atty. Jack Goldberger, July 29, 2006, Palm Beach Post (Ex. 4). "Defense attorney Jack Goldberger maintains that not only did Epstein pass a polygraph test showing he did not know the girls were minors, but their stories weren't credible." - Atty. Jack Goldberger, Aug. 5, 2006, Palm Beach Post (Ex. 5). "There was never any sex between Jeffrey Epstein and any underage women," his lead attorney, Jack Goldberger, said from Idaho where he was vacationing with his family. Epstein did have young women come to his house to give him massages, Goldberger said, "Mr. Epstein absolutely insisted anybody who came to his house be over the age of 18. How he verified that, 1 don't know. The question is did anything illegal occur. The law was not violated here." - Atty. Jack Goldberger, Aug. 8, 2006, Palm Beach Post (Ex. 1). The quotes above are just a few of the numerous quotes and information provided directly to the press and media by Epstein's litigation team over a two year period before Plaintiff S ever filed suit. In fact, as mentioned in the story, attorney Goldberger was so eager for media attention and publicity that the quotes in the first article cited were given while he was on vacation with his family in Idaho. (See Ex. I). After the instant civil suit was filed, Epstein's mob of attorneys and press agents continued to pepper the media with their "version" of the story. I Gerald Lefrourt isAvas one of Epstein's attorneys in New York. Page 2 of 15 EFTA00723523 "Are these comments not prejudicial to the administration of justice? Clearly, these comments, without supporting evidence, are nothing more than hyperbole and would never reach a jury. Nonetheless, [Mr. Goldberger and Mr. Lefcourt] chose to make the comments in an effort to prejudice....[the girls in this case]." "[Epstein's attorneys] forget their attorney oath which reads, in pertinent part: `I will abstain from all offensive personality and advance no fact prejudicial to the honor or reputation of a party or witness, unless required by the justice of the cause for which I am charged....[Mr. Epstein's attorneys] took this oath; however, [their] publicity seems more important than the very oath [they] swore to uphold." Above are direct quotes from Defendant's Motion for Sanctions filed in this case. (See Motion for Sanctions p. 4-5). Plaintiff has merely switched the names of the parties. Are these quotes not just as appropriate if applied to the comments made by Epstein's attorneys? When reading Epstein's current motion for sanctions, the often quoted phrases, "those in glass houses shouldn't throw stones" and "the pot calling the kettle black" come to mind. These quotes were merely the beginning of the publicity junket that has continued through today, with not only Epstein's criminal attorneys, but also his civil attorneys, such as Robert Critton. Epstein's team of attorneys utilized the press and media in a clear attempt to bias public opinion against his victims. Now that the victims and their attorneys are attempting to speak out, it would be a miscarriage of justice to sanction and silence the victims while the admitted criminal is allowed unfettered access to the press to pitch his cause.2 2 While Defendant's counsel takes issue with the branding of Mr. Epstein a "criminal", the facts and public record is a show that his has plead guilty to Ipirocuring a person under the age of 18 for prostitution; F.S. 796.03" and he registered Sex Offender as a result. (See Ex. 6). Furthermore, when comparing this plea to Goldberger's statement to the press in Ex. I this shows that Goldberger either permitted his client to plead guilty to a charge he did not believe his client committed, or he flat out lied to the press. Undersigned counsel is merely a civil litigator and does not handle criminal matters, but surely one of these two options is likely unethical. Page 3 of 15 EFTA00723524 Memorandum of Law Epstein identifies four separate issues as the foundation of his Motion: 1. The Egg Shaped Penis deposition; 2. The non-prosecution agreement, and quotes regarding same; 3. Five various news articles; 4. The Goldberger Affidavit. In addition, Defendant appears to throw in as an after-thought the argument that as a result of undersigned counsel's quotes, none of which directly discuss the facts of thee. case, somehow her anonymity should now be revoked. M. has never spoken to the press. Ns argument is illogical and should be denied. Each argument is addressed in turn. I. The "En Shaped Penis" deposition The deposition of Jeffrey Epstein was filed with the court and is a public record. "A lawyer may allow a newspaper reporter to inspect the lawyer's copy of a deposition taken in a civil suit of considerable public interest if the deposition is available for public inspection in the court clerk's office, if the reporter, not the lawyer, instigated the inquiry, and if the lawyer refrains from improper discussion of pending litigation." Fla. Ethics Opinion 65-43 (July 30, 1965). This opinion was further amended subsequent to the United States Supreme Court opinion in Gentile v. State Bar of Nevada, 501 U.S. 1047 (1991) to allow attorneys to quote more liberally on legal proceedings which have public interest. In Gentile, the U.S. Supreme Court recognized that a vague regulation of public speech is impermissible and unconstitutional. A lawyer, like any other citizen, has a right to freedom of speech. The Gentile case involved a criminal defense attorney's comments to the press (not unlike those already cited in this case of Goldberger and Lefcourt). In Gentile the court required Page 4 of 15 EFTA00723525 that any rule banning public speech of an attorney must comply with both the requirements of "imminent" and "substantial" detrimental effect on the proceeding. Florida's Rule 4-3.6 specifically states that "A lawyer shall not make an extrajudicial statement that a reasonable person would expect...will have a substantial likelihood of materially prejudicing and adjudicative proceeding due to its creation of an imminent and substantial detrimental effect on that proceeding." The release of the Egg Shaped Penis deposition clearly did not "materially prejudice" Epstein in any manner because the Palm Beach Police incident report and probable cause affidavit which included this description of Epstein's private part was a public record and already in the public domain, posted on various news websites since his arrest. See http:/lwvinv.thesmokinggun.com/archive/0726062eDsteinthiml (posted July 26, 2006). Additionally, there was no "imminent" court proceeding at the time the comments were made public. Mr. Epstein's case is not currently set for trial.3 In the comments to Rule 4-3.6 it states that "Wire public has the right to know about threats to its safety and measures aimed at assuring its security. It also has legitimate interest in the conduct of judicial proceedings, particularly in matters of general public concern." The Epstein matter is a great public concern as evidenced by the thousands of news stories throughout the world. All press inquires were unsolicited by undersigned counsel. During the litigation in this matter, and because of Epstein's notoriety, press agencies from throughout the world have been attempting to contact both undersigned counsel and counsel for Epstein. This deposition was filed and made public because Epstein walked out of his properly noticed deposition. Therefore, his deposition was made public record because of Epstein's own actions. Other than showing an individual's identity, there is absolutely no difference between a Page 5 of 15 EFTA00723526 written transcript and a videotape for the purpose of public disclosure as it pertains to Epstein. Defendant cites absolutely no case law that can distinguish between a written transcript and a videotaped deposition.° As a result of Defendant Epstein's actions, this court sanctioned him and ordered him to reappear for deposition. At hearing, this court properly pointed out that the questions asked by undersigned counsel, while personal in nature, were reasonably calculated to lead to the discovery of admissible evidence. In fact, this argument by Defense counsel is another example of Defendant and his counsel saying one thing, and doing another. As recent as December 3, 2009, Epstein's counsel was reprimanded by the Federal Court and the United States Magistrate Judge Linnea It. Johnson for their deposition tactics and questioning. A review of the deposition transcript reveals numerous instances of Jane Doe 4 being subjected to repetitive questioning about exceedingly sensitive issues such as the emotionalir caused 1 and Epstein's treatment of her. To re-phrase Plaintiffs' counsel's words, while it may be appropriate toilirlaintiff in a personal ilic i asestion abut whether caused her when the essentially identical question is re- phrased and asked over and over again, the questioning becomes badgering and harassing. Counsel for Defendant must be mindful that the depositions of the Plaintiffs in these cases covers the most intimate and private details of their lives and if not handled correctly may serve to needlessly re-victimize, embarrass and humiliate them. ...counsel is expected to conduct himself in a responsible and professional manner befitting members of the Bar and balance the need for the information sought against the psychological trauma 3 Alternatively, undersigned counsel points out that the comments made by Mr. Goldberger and his co-counsel in the press, as cited above, with the criminal trial pending and speedy trial issues, were clearly made to cause "imminent" detrimental effect on the criminal proceeding. Conversely, a Jane Doe or an anonymous Plaintiff is entirely different. A proper non-identified plaintiff is afforded her anonymity because of the illicit and illegal actions of Defendant and Plaintiff's age. Defendant Epstein is not afforded that protection because he is the perpetrator, his photo is on the Internet as a registered Sexual Offender, he is a known public figure and has been identified already in this proceeding. Page 6 of 15 EFTA00723527 that could result from repetitive, humiliating questions regarding the sensitive issues at play in this case. Court Order Dec. 3, 2009 (Ex. 7). While Defendant now claims that undersigned counsel's conduct is somehow embarrassing or harassing, it is Epstein's attorneys who from the nexus of his criminal charges have taken a sledgehammer approach to discovery and publicity. The Defense tactic has been to bludgeon Epstein's numerous young accusers with negative press, heavy handed and intimate discovery questions and harassing deposition questioning. In no way was the release of an already publicly filed deposition improper or sanctionable. IL The Non-prosecution Agreement ("NPAn Defendant's argument about the non-prosecution agreement ("NPA") makes absolutely no legal sense. Similar fact evidence of other crimes, wrongs, or acts is admissible when relevant to prove a material fact in issue, including, but not limited to, proof of motive, opportunity, intent, preparation, plan, knowledge, identity or absence of mistake or accident, but it is inadmissible when the evidence is relevant solely to prove bad character or propensity.5 Fla. Stat. § 90.404(2)(a). In Florida, there is a general rule of admissibility of relevant similar fact evidence even though the evidence points to the commission of another crime. This evidentiary rule is commonly referred to as the Williams rule. See Williams v. &ate, 110 So. 2d 654, 659, 662 (Fla. 1959), cert. denied 361 U.S. 847 (1959). This evidence of collateral crimes or acts is admissible under s charged with a crime Fla. Stat. § 90.404(2Xb)1 thither states that "[fin a criminal case in which the defendant is acts of child involving child molestation, evidence of the defendant's commission of other crimes, wrongs, or molestation is admissible, and may be considered for its bearing on any matter to which it is relevant" While this is the policy behind this not directly applicable because the instant case is not a criminal action, it is persuasive since subsection is similar to a civil proceeding for the same, or similar, acts. Page 7 of I5 EFTA00723528 section 90.404(2)(a) not because it is identical or even similar to the crime or act in issue, but because it is relevant to prove a material fact or issue in the instant case other than the defendant's propensity or bad character. Zack v. State, 753 So. 2d 9, 16 (Fla. 2000). This type of evidence is sometimes mistakenly referred to as "similar fact evidence," but the similarity of the facts involved in the collateral act or crime is not the test. Id. Here the court need not even address the issue of admissibility because the parties are merely engaged in discovery. Clearly, there is a good faith legal argument for the direct admission of similar fact evidence in this case to prove motive of Epstein to commit the sexual battery upon E., opportunity to commit this act, his intent, preparation, plan, knowledge ()f.'s age, identity of Epstein and the absence of mistake with respect to the girls' ages. All of these issues have been raised by the Defense. Regardless of admissibility, the discovery of the information in the N.P.A. is reasonably calculated to lead to the discovery of admissible evidence. As a result, through the proper legal court proceedings, undersigned counsel joined in a request to make public a document that did in fact lead to the discovery of relevant and pertinent information not only for the benefit of his client, but the general public and the system of justice. This NPA showed the previously secret deal cut by the U.S. Attorneys office with the Palm Beach State Attorney for the conviction of Defendant Epstein. It also identified by name co- conspirators which were given immunity. The NPA is also relevant with respect to the bias of Epstein's co-conspirators who were given immunity. See Fla. Stat. § 90.608(2). "Any party, including the party calling the witness, may attack the credibility of a witness by:...(2) showing that the witness is biased." Id Is there a possibility that a named co-conspirator/witness may be bias in the civil proceeding, in favor of Epstein, because he negotiated for her immunity and freedom? See Morrison v. State, 818 So. Page 8 of 15 EFTA00723529 2d 432, 446-47 (FM. 2002)(disclosing a witness's self-interest is a proper purpose of attacking the witness's credibility). Without question, this is relevant cross examination material in the instant case. Until the release of this NPA, undersigned counsel had no way of knowing the terms of the deal or the co-conspirators provided immunity. Regardless, the Fourth District Court of Appeals granted undersigned counsel's petition and made the non-prosecution agreement public. See Epstein v. State, 16 So. 3d 315 (Fla. 4th DCA 2009). This document also has direct implications on the allegations of Plaintiff's cause of action. It is now an Exhibit to Plaintiff's Amended Complaint which shows the broad sexual enterprise (i.e. R.I.C.O.) and co-conspirators Epstein utilized to abuse underage women at his home on Palm Beach and elsewhere. It strains reason for Defense counsel to claim that by utilizing the proper legal procedures, and winning at the appellate court level, Plaintiff counsel's lawful conduct is somehow sanctionable. M. Various News Articles Next, Defendant cites various news quotes from undersigned counsel relative to this proceeding. As previously stated infra, these quotes are within the constitutional mandates of both freedom of the press and free speech. See Gentile. Furthermore, it can hardly be said that Epstein's counsel has taken the tact of "no comment." Mr. Epstein is a man who has not, and does not, shy away from national and international publicity. He even has his own Wikipedia page on the iMemet. http://en.wikipedia.org/wiki/Jeffrev_epstein (See Ex. 8). This is a man who, long before the current litigation, had an international profile with friends such as former President Bill Clinton, Actors Keven Spacey, Chris Tucker, David Copperfield, and financial mogels like Les Wexner (owner of The Limited, Victoria's Secret, Abercrombie & Fitch and others). The facts Page 9 of 15 EFTA00723530 surrounding his crimes were national and international news in print, television and on the interne. One need only Google "Jeffrey Epstein" to find over 36,000 stories on-line. (Ex. 9). Mr. Epstein's illicit actions are even contained within published novels. See Learner, Laurence, Madness Under The Royal Palms, Love and Death Behind the Gates of Palm Beach, Hyperion (2009) at p.175. The premise that, in the midst of this media deluge, four or five quotes by undersigned counsel somehow tainted Mr. Epstein's ability to receive a fair trial is laughable. Attached to this Response as Exhibit 1-5 & 10 are no less than nine (9) news stories containing quotes from Goldberger and other members of the Epstein defense team. In addition to this legal team, Mr. Epstein hired professional Hollywood publicists in an attempt to spin the media and attack his numerous underage accusers. (See Ex. 1). Mr. Epstein hired finned New York publicist Dan Klores — whose client list has included Paris Hilton and Jennifer Lopez — who was quoted as saying in an August 8, 2006, interview with the Palm Beach Post, that Mr. Epstein was ready "to get his story out." This crack legal team and publicity engine gave numerous interviews with the media in an attempt to smear the reputations of the minor victims of Mr. Epstein. In opposite to their present position, Epstein's counsel took a diametrically opposite ethical position, in a similar sexually charged and high publicity litigation. While the facts of that other case are irrelevant to the instant proceeding, the legal proposition is the same. In a case involving allegations of sexual harassment and battery with a high profile plaintiff attorney from Stuart, Epstein's current defense counsel freely gave interviews and information to the media, such as videotapes, to the press. (See Ex. 11). In this other litigation, Mr. Pike was quoted as saying Itjhis is nothing but a shakedown for money." (See Ex. II). The Critton firm then filed and made public the content of sexually Page 10 of 15 EFTA00723531 explicit DVD's showing the defendant's adult son having sex with one of the defendant's accusers. Pike was again quoted in the press saying "she claims she was assaulted by the father, yet a week later, she's making an amateur sex video with the son." (See Ex. 11). Mr. Critton is no stranger to the media either. In the past he has given numerous quotes to the Palm Beach Post about his cases, including one where he personally attacked an opposing litigant in the press by stating that "[he] has a pathological disorder." (See Ex. 12). Were Critton and Pike making comments in an effort to improperly prejudice the public and potential jury against their client's accusers, or were they merely exercising their First Amendment Rights to comment on evidence in the case? Critton has even given direct media interviews regarding his current client, Mr. Epstein. In an extremely ironic move, after filing his motion for sanctions against undersigned counsel, Critton gave an interview with the national publication AmLaw Daily.6 (See Ex. 13). In that detailed interview, Critton was discussing his recent filing on behalf of Epstein against disgraced attorney Scott Rothstein. The facts of Critton's complaint deal with the civil cases against Epstein which were handled by an attorney in Rothstein's office. Critton told the press "instead of a defendant having a legitimate discussion with a plaintiff to resolve a case, [Rothstein's] out there pitching millions in dollars from these other cases he claims to have" and further claims that Rothstein engaged in "abusive litigation tactics." Critton further told the press that he was seeking "at least $100,000 in damages and more than that if damages are trebled." 6 A Palm Beach Post reporter also advised undersigned counsel that Critton's office dropped off a copy of the Complaint against Rothstein the same day it was filed with the court. Obviously, an attorney trying to avoid press would not voluntarily drop off a new complaint to the local newspaper. It is clear that Epstein's team were actively seeking out press on this issue. Page 11 of 15 EFTA00723532 Critton appears to have no problem with quotes to the press when they favor his client's position. It is merely when the victims of his client speak out through their attorneys, when he takes issue. One cannot use the Rules as a shield and a sword. None of the statements made to the press by undersigned counsel were improper. Additionally, none of the statements cited by Defense were prejudicial to the administration of justice. Quotes cannot be read in a vacuum. Both Epstein and his victims have had equal representation of their version of events, and the allegations, in the media. To silence or punish just one party without the other, would effectively quash the constitutional freedom of speech by victims and their advocates from speaking out when attacked by their accusers representatives. IV. Goldberger Affidavit Of all the unfounded accusations outlined in Defendant's motion, it is the Goldberger affidavit that is the most disappointing. First, undersigned counsel denies the statements recounted by Goldberger in his affidavit. Second, and more importantly, it is a sad day when colleagues in a difficult and stressful profession cannot have a friendly, joking conversation apart from their usual advocacy and courtroom arguments. Frankly, the fact that Goldberger has filed this affidavit speaks more about him as an individual than any other filed document or quote to the press in this case. Undersigned counsel will show more discretion and not recount the similar out of context, and joking, comments Goldberger made in this same conversation about his family and his own client unless the court finds any merit to this argument. If so, then undersigned counsel will provide his own affidavit quoting everything said during the conversation misquoted by Goldberger. Regardless, this conversation had absolutely no bearing on the current litigation or either side's litigation strategy. For Goldberger to even try and use this friendly conversation as Page 12 of 15 EFTA00723533 anything other than two colleagues discussing and joking about business is distressing to say the least. Unfortunately, Mr. Goldberger has shown himself to be an untrustworthy and unfriendly individual. That is just sad. V. Anonymity of Plaintiff, II As an apparent afterthought, Defendant somehow tries to leap to the conclusion that based on counsel's statements to the press, al should lose her anonymity. As cited above, Epstein's counsel has "solicited" untold amounts of publicity for himself. Conversely, not a single statement cited by Defense references the facts of M's specific case! The first case cited by Defense for this argument is Doe v. Frank, 951 F.2d 320 (11th Cir. 1992). Ignoring for a moment that this is a Federal decision interpreting Federal procedure, Defendant's conclusions about this case and its applicability to the instant situation are awkward at best. Undersigned counsel can only assume that this argument is a cut and paste job from a similar motion filed by Defense counsel with the Federal Court in other Epstein litigation because it does not apply. Defense counsel properly cites the seven factors in Doe v. FYank which would afford a plaintiff anonymous status. See Defendant's Motion for Sanctions p. 9. Two of these seven factors are directly relevant to the instant case: "whether the plaintiff is required to disclose information of utmost intimacy" and "whether the interests of children are at stake." In a baffling display, Defense counsel then states in his motion that "Plaintiff does not fall under any of the factors." As recognized by the Federal Magistrate, this entire case is about intimate sexual conduct involving minors. Furthermore, S's identity has been known to Defense counsel since the inception of this litigation. As a result, all of the caselaw cited by Defense about "the purpose of discovery" Page 13 of 15 EFTA00723534 is irrelevant. It and undersigned counsel have not done a single thing or taken any action to prevent the orderly discovery in this case. Further, Plaintiff does not disagree with any of the cases cited in paragraph 21 of Defendant's motion. The courts should be open to every person; but how is that relevant to revealing the identity of a sexual molestation victim? To identify a young girl who was molested by Defendant as a minor, serves absolutely no purpose other than a threat to embarrass and silence..'s counsel and any of Epstein's critics. Unfortunately, given the Epstein team's previous gorilla litigation tactics in both the civil and criminal proceeding, it is not surprising. Not a single case cited by Defendant stands for the proposition that comments by counsel regarding a defendant somehow vitiates a Plaintiff's entitlement to anonymity. As a result, this request should also be denied. Conclusion For the above mentioned reasons and argument, Defendant's entire motion for sanctions and to identify should be denied. 7 Interesting to note, this is the same tactic that Epstein's counsel has taken repeatedly in the cases with other girls (i.e. to threaten to identify plaintiffs if they speak to the press), while alternatively Epstein's counsel apparently feel none of the similar constraints. Page 14 of 15 EFTA00723535 CERTIFICATE OF SERVICE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. Mail, postage prepaid, this day of ac o , aov, to Jack A. Goldberger, Esq.= Bruce E. Reinhart, Esq., Robert D. Critton, Jr., Michael J. Pike,. LEOPOLD-.ICUV1N P.A. Esq. 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Sitte Web iihvt. yanect hnett Lases Gar net Odan Intro athasive env: Horne s,- terse. Opeold: 11222LUB I alaittRW~3 EPSTEIN'S RELEASE UPSETS 'JANE DOES,'THEIR ATTORNEY SAYS BYLINE: SONJA »GE Ft. Pan Bosch Pa She W rlie- DAM 44 23.2O09 PUBUCATION: Pea Oka Pont. The fel) arum FINAL SECTION: LOCAL & BUSNE SS PAGE 113 MEMO: Gel shwa up Mend Simi cesolde eta the .Wtey Epstein case. PeimBoarPcst cOntrepeten Epstein sOON and on Jere Ca No. 6 dd not witch Natin Wedrear/ ~Nog. CeNe »NOIONG ettanterate ateY 13 Na Pan, Bead, Beasonly. a he calked advise Pia Beech Corey Jii end •YPPed la a Cr an ad No, bock Mtn!~ ton tun to mete It wigy. 1&awn eetego And Yea, the hitayegrald It now. itnyelend *ea "now v.he Its dale his tkno - ree risito ID mantra d an Metes= ran annoy», Ce ceotan. Cheat» In weekly *CT h• goren Cane. aereehday. Ba Jane Doe No 6 tee an. who ha Ned lawsuits Ivan font in the worked NL any Wo and autaCch at poeet. eva Vial he was read WC% a me, torch retailed Want:~ wilh =nay Eed ~IM O» bar may mare« on bone of yard wan who clam to nth been A!"! a *nun MinAns hat INOn IJs «dimt ran they wins tons 'Tea as has any tame. »a we warm to hoc tied ~as skeins, Mr. Epstein end we We chance them: Eppoinh attorney: Jack 001dberpert. said you renkat dikeen Roane Catitegors mats online, the entnyrrcus Ms. Doe teed Nael: 'Ca an not sidles— wild add tinny sesoutled by n Oa' men! Nos 22. oho set she c wham; In Nth add yea Feria esnuiCy Cased her She was Ws-ninon:0 OY nie °tau& money ard poter ho Sae& she sere • Nor ender no Ora by Jane Dec Nos. 2 honk 6. says Ada Horowitz, wto mastiff each en sescra era llsno timed» and cares fled on bail ce war aged *time dehaibt Epteleint peal ce cede nierisaccs one a yohil Bar pay orkn Macy. tor Ilse yang women - some aim te hone been as Bred as 12. fantod to liow1Z -soy he tirdded n torn he reread lobo weal), to tell or whose eredltdIty cold be eetles into qJeistion And 'te Sae &Need to Non Co , It, sane cases on El Brillo Wey by rtitear sNa lis chests anew in LacensaChee end GOyd Palm tech led von dick taken to the ~mien task FeC4thLien The dad he Epstein daadtin gay In Joss 20» to two letery dwpn. pleCtaina a ace br coca ttian and &alley Count m000 to gel on Wrenn conc.», is sored. thOUCM ths: een le ome plop charsilen n 1Vhstri he vaS serieeed. thy were eh:~ It sizet nel: a attract Nora./ sea 14C Then they kind he ~sot swain int thet time in jell. ~crag to scot. Epstein an handier/ rattly al Lorne weekends enne last OCkhor os part ci a solintotee program. /le sealt het erne, ~10 Fonda Scarce Fete\ o: mot : td te i tt neemt! te ~Eh Wan he ma schemed. No. the man's aK now.' areas ad. "They at ney ashotel Some teal say wattle MC heb out on the street des Farad cells to E psi/Wie attorney We MI retuned. ACOWIIM nut ACSINteilisacerM4OKY•tarObeb,~~cáiyetoOnAPOIM1309319arts,•.~.104.01~.0.1,44.2aninr•t•w ~S.M. EFTA00723539 11:40, :2119, O•Me.cM,a•i.mRMIYMMI)<YtrslMriMiWllacion•nen date: amp* ce An DNA be lho Fa Vic net yea. Eaton mast Check in weekly oat et patio ri Oka Not no hate to Wets Oaten °Senders muy rot l As be Coale.'" Kam tome. Pan Bosch nas on stole law to 6«ermne Mase rt4 stew an 1,000 kot tl • alma ark oe tad am cert.. Ha manta ant dew d all ace zeros. Sat manna mots tstorionice oontetwas 10 out nay ratan app"N.) 7X9 INior 0.1a‘ Featured Jr>bc. VEMIC~131.1116,AVACCEl 3RD pryccutcnofri SAWACER Eecaent COVLin9QtiVt~ CDVEIRUD1pN10DgSEFYER. Fa NOS ___ ~MN" PlaCHAGINOWHACER $44.4911 Pon PI01~ WOO«MIRE WOW HOME WALSH ilaNCYfrnmaked• Vny m, Fteturta Jot., ',er~ 02008, it Pala Bach-Post AM eras ~et utiogPatraciachPostooetn you ocapt at sewn Mow nitair sigann tboantlidt Calblnik41~1~1q• I Chat= daSszliscetit~ ....,24t4,8ecreal.lanhwevni•Iluanlks,"~“010.40114P/1111.0••.~~14.. ProtNl rt-abou..e.-"ariparnises temati..-~ caa..taxd• Val Wit‘ItC3, 30"ew EFTA00723540 rt Hr. Vert rvr. 20,2e9 1112 AM MOGUL DOOGFc :8.3110.11 C kit riCr MOGUL DODGES JAJLBAIT CHARGE New Yodt Post- New York, N.Y. Date: Jul 27.2005 Start Page: 014 Section: Page rot Tae Word Cant $95 DoourneMhat IT looks like New York ttlioneire financier Jeffrey How to make e lectricitY Epstein got off easy when ho was hit with s charge of A shocidng new horneowner's kit the electric co's soliciting a preset& for a "napPysndirer in Peen hope u vAll never own Beach. vesPoveMlionweem Because It Palm Beach police had rear way, Epstein. 53 - who eurnmdered last Sunday and IF out on 53.000 ball- mighthave been whacked Witi tar more Search multiple engines at once for newspaper serious charges olpaying underage girls for sex archives wentwebanderann But a sego randier/bond the witnesses in the case were notittedible and threw cattail but the single deur Meek:ging a hooker n his hoar/Sous Perm %Mat Beasts home.Epstein lawyers and Mends now say What concerns you the most about today's health he's the hapless Vetim of a vendetta by Palm Beech insurance system? Ponce Chief Manse Reiter, whom they oesenbe 06 a ItorAten commetondeNay 'Immegaln nut case? Acconcmg to the police investgation. a copyof which from 17 witnesses and flw alleged act ms 20. a who described herself as like a Heice Reiss: vase she got S.ee naked lo give Epstein a massage. Mn brought him slack's ages 14-16 for messages and sent his home. said theywere paid $200 per session. Cops also allege that Epstein's personal assistant who basal been charged, set up the IFIFFOFIS and garbage end put trash sheets on the massage table and supplied massage oils. Police searched through EpslePfs retriesed sex toss and feminine hygiene products. the caps had Epstent Palm Beach lawyer. JacitGoldberger. bid Page Six the the Florida state attorney concluded test lookedatevidence from ii terie-S kited penspec5n.' He sated that Epstein had passed an ostensive lee-deteetor In which he was grilled aboutunderage pins. in ttvs case. but Epstein New York lawyer. Gerald LOW" sec, The prosecutor didn't want to bring anycharges because tot the vainest Of this paws chief.** haw the charge of solicitaton? A spok•SWOman tot Reiter said,strer think our knesfigolion speaks to leuvoeurea with Dterat!Cri of the merlin Ove4f. FWaer ftPtOduel:011Ce digabubon inn/need without PerentiOn. Abstract (Document Summary) Cops also allege that petty EpsteinTs personal assistant-, who hasn't been charged, setup the liaisons and put trash sheets on tne massage table end supplied massage Oh. Police searched Ihroof$IBOstelnt garbage and retieved sex toss and fernhese hygiene products. he cops had Epstein's Patin Beech lawyer, Jadc Goldberger. told Page Six thet the Florida slats *bonny concluded at midence horn eckne-s tried pers pease.' He added that Epstein had passed en etans lie-detector test looked in which he was grilled about underage pins. oftaw COPYWI ow nr. PlOthe, MWOOKIkal Of did/SPAR)," IS CIMM011od w maul pOnniattel. RePrOduCed vnth PomialOn lanwnciedest•MOGallaDODGESOAltiart•CriAltefter.1 P55 sal) htemitappeaver.aefilfregRatsit106432M0ibeltilds.10M327. 44•PCOSeatbeo I EXHIBIT I EFTA00723541 Rak nami OdeIsetele PSY We% MeaMN. ateweepseistmeeeptsesee PalmBeachPosicom i Archives •••••••OWIti.04 Web Aulos R04, Ilelobs aw cis& Puwp4b• aha kasa sio Jots Weetrc: Tr.or.• Drs.*, Wew(' Esegatilinc= ftetw. Krn. thy Votb.• 6007 W•wl CaSelt &fksieIsis a Nroyaush POLICE SAY LAWYER TRIED TO DISCREDIT TEENAGE GIRLS WHAM LARRY KILLER. Palm Stach Pat Stać Yen: DAT": J.4 ap. 2000 PUBLICATION: Pam Beach Post. The (EL) WTOK fNAt Stalak LOCAL PAM k MIMO: at dl amen Oko ad patowi alka Filmed „nid I.. wolesG0c Alan DestmeN2 met see Vs Pam Babrz Corey Sum MIGOWO ciwrpecl swassapas, lasowa obar leers;. guts who say they owe Ns dat Pak Boa barowa Je*ey thaw. sartaly obawa w pola ropa. torn no cara lb. ara alto ate bol oak Easters atonia/ mrowi to • pea bran eat void low alba Epstein one Pd compared warz had arat atomy dola ta isaak. NW the docatents also real that the bardonowi his lame and abs or tisiwy ea taka ankkalces aparesstddi trarsal Ns cr. reaktrzalled arce oho terzed to scrokCCy Ww sad rte was doted money K she rased to wara ta the Pks Beach Pace Dad rnel wata of Cahn hol nudy asa jury his reak raba an dray chata TYra stok Moan tace said k sawa the Eaten. adr .oskam twa beam Pacom OWA wo Pni credeonty. lm ona itry taca Epelan. M. on • ago osadka ce prosaka kich aches a madam yenay d he years h Tria acts irk a aver sad Piu bawd here at path cewa to char Ewa WINI* MPO WWI cam d asa ea Kleista memos ad end Meath= watka Poke Oat Maar Rea was so ai MC ho wole SUN Mln( Sadrz May haman° he karzy Wwal acha Ow caw Be gardlm h Feacry, bA was poshati ate Ocrshar prodarod Mn cam spindly was Goa to be owad to almand are Ileeklane Internalen peered ram the Web she mapa cere ohootsv sane c! sad ene(sX1 Jaime ovemening m ocCang to the baca art Paborzd by Oecicbm atat Recede/. a oho da In Ark. According to Ramy, paca Lae achatt dka Epan otanks llersaaas Gw Fiona kateted nawa Frowan, ker sakwa att Epstei4 kapsl he tantach Epilell woal plead hary to ar cowl of Tae Oce sto ala to•Epslch to with :MOM tama afany. be pad al he yeirS' patiom end haw no carat ma ID Recasts repot The ha. aka to a psychiatric ara sat atak and hiw no tasscanlaad gilts MIlt haras. karta bash mode In ansa"wBh my ada Ow Mego] sarna the Wat states. ka Gola botem n. Prany,, • who aka to camera on Uw omy • to. easequenhy Fed asa wian draw away Nred. Noakes kere a fl arroanall MW ct Ekleres kanop babrze da. allorzat spokesman chef be 'Wc ebsdatty 64 a ace rz epa n VW sae.' he said. 1C&ct Bata+ washer acta te COffelell. 7116 wet v patens ct aged Ucha Kk Caktabal d ang Massed By poet trakatar ara Were Wroto,* 1ss in haler. d No of the as Pora kard the trias worz nastawi kapka eye Wat Pa Beach end pawia ammana to Rama repom 'r hews no knoMathe d n,' Cake dank Orkaate mm. who twe ela n torah wab Ekler. The nwol 820 Mrze a wam comasiod to ho eaten case ma cotaCIOC by somebody hose who did la 'wal kat pawn rac her ate woja be cmhatawahrd amp dal coopreate Wth posok Ratowys nowt says. ha be cost \Pl=311 said she as ta nora roka stow she war. laud with P2 Plan at Mady hadated awal Me Snie She ad Rany Wedet słACOIWI0110/10,12aarrashanw Po i el IttPITCAMIST•śmatniearpeoesCramaiforwenSOJIalhintitsunnamoAccno arullbjeashrlarainwStsgradarewe EFTA00723542 BOO.C4 Ho* AM OM re it ea so, rm. POOOP girei,01 also show Ind b• person sale lo lea made oe bred ben ~Saar to Easters persebe asaltlark she h turn celled • Hen York corponnoneSlaird Mel tannin. tro repot slaw TM Usu. In the Lamm (baronet alhr limbo ere to ha %Met« Ion., in ~a he anew Ob. ors •Hey new *rued or came to IM rone: ~bar Said. Bek IOW, EMU«, "at Vion a PPYawn led, 'he Fasten en ~dear dogs: the theme( add FBI 'Wade nabob Alter Vie edelrrenl moot Egnoln 'nos unmet« ads week, Pocce CISNRetat hared the male to the Ile Men. ant note redone% It: sod FBI sookeskonnonlJO( Og In Mang he bs o tOlf,, We Now Yon "le eNW himksnas cony at back Pon Eboafa Wye., eed bade In New Yak. wen Post Quoted Esomins pun t New Yea soy X. Cob1/2:101(obl. es saying rks chat was Irslatal say lounge of the ~sr et the poke Wet.' Rena has ~Wed to ~me« on Po C954 b ProstaAcea hint not preseabel a sta-rdatot ease like Epslelnk leopard My betre. aap MIke Eameetkon spokesman the state attorney's oboe `Theo MM yea do with a aft that bin ede a gray area: he said. The state attomey's take 44 net recommarlapatratacCAMIna aurae 0.133.011t0 bib Pastern (.334 043"3, salt The Peed of the mom, he sold. lay tale ananin0 watts NI et chows eon Wool to Wool. Man adibonace kath the Moaners ix1 SY be Wools In (Wafted at Ow yard Iwy pronto/Oa' West Palm Beech *arse eacaney Raab Tana sad 'Is a tan posionvbe• oase to rot taw the IA noterarokty b rd MN ee lane). And not PoIng Slot the Pam Boob Ponta Deptelmad on* IPi P sonothlry tea loon wan that undesge wan: teen ~ye a tronntson Ir. I W arne orgy Robe Gerstman wt a amebae, b sa yen. *These pat bat time GLIT knot(' he said Wow barb • 011(mayi sad Eteldn's case rains the Site oe whether weary, corrialtd Ottenents Ike Conlon • ra w he wers ee sufara c< a lofrot kmito Prenten Paean hod Bone Trumo -we ~ad ade,rdy tom ahem. Oea he ~do& el the ~ha: mono. Eaten hood • ~Lots and:eV atiancre sue, et gort Ne end ledocal. racketed Netlona Assorteer ei Olmen: Oterree Layers. Men/ lawyer Roy Black -Mew recent nekorolly boom when to sursomsbly °ebbed Willem Kennel/ Small morn ehnlie In Ptah Beach -also war booted tent pVd. may be Said Oaken ammo( lachel* Stramon ri think Es urtotonbe the bone may Set the Peo39 3to " 4 ~ 30330. Tea Vested eldertvely than re tols100 333 Moutmtlen: PSI7r0 (C) Jenny Epstein Its tenor arni Weed snobs trapiin, poke aso. (Mug) ConerrreitOit P•V•1400~~04" Fdttisred Jabs AilianTSC IPT~199. Data. el Nunn% Salerno say — QuNDYSiatim. acalt CounriClub Man $24 Moon ~chow WS2.1~2.911 CARPET Wal l/4 ROINMUOI5.... 60YEEMPAICSPALSRCIAMT SOVER1151310 oile.-96s~evn.a.onievitiniánv.WAC0104.1011t12:9371amogood....n. on. rea EFTA00723543 /*We IL+1 Av AA+.. w er wen new v4 t,, tintem./.• HisilliNtiMpsee PalmBeachPost.com IArchives wee IONA kg Aloe Real Eta Clessiecle Sheints teak ~c .w.on Web Job. tarot Ilan FA,* &seinen Ortarro-c Dan17.- Wsp treerinmem PhMtt Vint's. 'Alto Neg.: St iNZ:e5. fauttk I Aladidinainrati EXPERT: IGNORANCE OF AGE ISN'T DEFENSE IN SEX CASES MGM LARRY KELLER Psi,, Bann Peal Mad Was DATE: /soil 5. 2006 PUBLICATION: Palm leech Pad, The (FL) EDITION: FINAL SECTION: LOCAL PAGE: 18 MEMO: Ran en gigot N. Ewen If Palm Beech many renew Jeffrey Epstein 64n1 know that !pia *to pate say paw min sexual mucosa Hamel really net Intro:oasts/ hose wen undo tat tegel age. that None skint haw eteemptoti tin torn oh. ini Once a S3 yews, 'von is het ewed delete, sad Bob Dint, *legal tubs wetness, wee was s Lake Oly pesecuta tot salt y knetieckp element as bas the age a corgennad.' half (Feet Urns SPeOsaling n eta elffr.et **Int cheocren. 'Them In re Mkt ski Win tecthiJ sex acts Nero" t1•rnssh ineettelice. Pawn Booth police salt, them net probable Clicae 10 Cline tea in. V.% Meal of week a ranee and lewd end wallow mcitessien. They =Mot mai Egetet tot of the ach r4 tame at Snit* Dentoonele Party ceparteetkee arse cartoons • oamerated troso see with Ine aw•ape yds. n the psi vrteit. New York Attorney Gen and albennteita castelete Etat Soto tga marred tall 250.050 In ComPace 110.400 to conilbelcets he meshed Iron Eget** end Ma* Green o made, to mien Stow In he can bob Net returnee hire beceoSe of on Pink Beech sand* the New Yolk Da Wes tee *Parted set Steger Man We cloven, the state soarers abbe preened the case so* county wend AO. The Pend Wisted Elton* l scenes WC*, loss anima throe el teery teiegetten of peitiltden. -dm, And c Increnot The ease mbar) web-owe because cow ewe ettOcleye ogee rangy. revo,Itteke sue cNcg•n were hgtt-picet1 tally 0 pe06wating Oncl so Steno cases. cogeditty when to Wets* b encrmousty wealthy and can h* tooter Mayon. nate ler freezer, end At least an d Epstein rept Joint told pelts ho knew she wee indoor when the twat decal pet to police: segue! catty. 5In was 16 neva obi at tho ante end sod Ewen asked he cannons Gni la Mph scheaL escadny reports It hone, bad things A pal rho said she me Epstein when she was 15 rid he told ter Y. she tot eeyboly wee happened se cat happen. Me Poke Mon Gan Whit. She as now EMU**. yerandeS1 easged song vas 14 sten she says she par tern o massage Ortg It'4od writ Saul it The 911's Wa says he don t knot/ whethe• she act Epstein kw age 'Wry clateder as kept 0 let vAnr reopened toe me tang 6 shoo casecerassrnert.' lit Ike ebe wry mien toted TA Any rudPil marteoukt tww 100 aura! IIICYgra SPA Wenn Sternly Jack Goldberger mainline the not Orgy cbd Epstein ins a pcannaph test atonic he 60 not tee the gide Ines en Issue vAwi II was etas, Pith* slabs weal Creclie. The slate 4110.ney'S ofko also ImpLed the: Their ctedbity deckled rag to chars Epstein dimly. 06 Weft ONO the case to Se Got goy. . 'A posccutor has to bark at, I In a much beode• bslicet: a stele esomnyt erobevnen said last week end Dorshomu pert Epstein heed tenet taw Prieto( Alan DefOgrall VANIP1 he became swat he was Cale• irninegallon. see. PeSeagers Inlertratiew that some el the weed Cedes had ercko 6 Wang aeons we, reefewria on a Peedee Web •ccodrg to a Palm Masi *grin moot. Pronto= tysicafy comber Iwo Pinot In decking whether to charge sonnet* SIN seurelancl *Senses nett mine* age , Mete Is stair% reeal one neater there Is a putt* intent In sing ea Oat Bald tl 0510214171.1•24j.erSitie. re /op I e Ir-JP21067.11, 4 CinahlieVatlArOth t.s.V"erntimiluir..o0.• :131USNA COMS3.%eaut--.Se, I EFTA00723544 aim 11.4Y ONAt lent kr PS KS. kyr innI WM fano. ee f$ INS wan *Moses otto I the se. V ITC Ieco I VI In • UMW velexsish:p and DIe Coy turns 16 beta the On. he Wad be charged Pass. There road to no sullic beeves's-. ounsteng Use, Der* said Maas • from Is • fikflic Mouth But seen nee Is S. Ib BOP n pee • and sepocaSy In owes et lesotwit wen pitsecittem. he SOB Likewise it the eCCUllel has a track wad dies MIT Janet. ix sex oleo SUE Ben it • steirrsteitanstart in prostOuting these cases. Dade as Man who espied tramp glisten catettly Owe* heir gams In My* Owl WI mininne the that to Work he slid. Maw and. Yams teveity we Itote • Iowa, sober sego.. and they bey bob from penciesecat robin Ten the act el abuse ore:loon tat a chid sent erase slctens he* been Vellmized by mullige peep, oar a poled el Ems. ere enr3 •Ba. betrayIn the Valan MX toter clareges Peet ekkittarf." ExaTateek Wake Paintaaktut tan swab's are the $203 IC Son* et the eileged Jan* to the Etielein salt retained fa his hove maple ernes be the grosser ire restaract SiK0 he type-thy paid Mir pr Veit. 'Thal acted be ei debit* pithier bin the rtriecaer; aid Bay Rasa breaker In take Worth Watt aggro' denten in Palm Bosch County lot ha yews one now Is In oche* 'The *Ion bacon= less synallictif los)" Reich said TM She's a Octet hhertlyhiss She's a ' Ant Mom men carped with sex sexes spirt( minces task namS. Mak art A pay expecting to eke a monster beer, wit. the edgers" ease wait assensl them el, it lea et the diardWit heel* Done saki nice DM to Wane be adds. a child end in schO to Ogren, stases and both swear they* Whig ant with MA jinn aye Doke Seel ea-ati h Ping 'You ha* ail those things WWIVIO erns' you In • the sex abuts Cain. Prosecif.as namely try to be .e' Chid seam abate care' those cases because Pry turn *se reser pelting kik). MOM a no nth sting b w intencled tstry_iudelasbeettorn Ulaitracer PHOTO (C) Jens/ Epstein'. The pea: ens hest returned donalons sive he Wos charged wen reciting e'en (exig) Copy...VW WA Pas seep+ srnix•Pro 11 Featured Jobs 0821GISRALIES. SCDICOSE SUER BUSY KBE HEM* MARC, knensdiste caeRSB CATERF10 SOPERWS01I. el - 011 LX5C6WS55151 LIG& ASSUSTANIT to AV end PIG. _ tivAg *VAC SEANCE TECHetiCirei.SE 11. Omens . v.... R., Rater: Jab: Copy* ri 2008, Tit PalaReathPost A0 tights named. By wingPalmIkeeliPostecm> >tea accept tha Cc Moir >Idol reset please matt a, CPINPaglftiggile2M ratIcnillet I (Bahgett AtibBefer th h Trc Peg I Aria' 305±6124 jsrwm.copepskspy....40:04: gtosnipale.wysearn. So- 2v) ParfrOrmea"AssemsnoStres90.40:•exSok•SILMWACC4141111%6XPs. aS.35.bconvessu EFTA00723545 Florida Department of Law Enforcement - Sexual Offender / Predator Flyer Click Here to Track this Offender Designation: Swami Offender Name: JEFFREY E EPSTEIN Status: Supervised - FL Dept of Corrections Department of W35755 Corrections N: Search the Dept of Corrections Website Date of Birth: 01/20/1953 Race : White Sex: Male Hair: Grey Eyes: Blue Height: 6'00" Weight: 180 lbs EPSTEIN is registered as a Sexual Offender. Positive Identification cannot be established unless a JEFFREY E EPSTEIN fingerprint comparison is made. Date Of Photo: 08/03/2O09 Aliases JEFFREY EDWARD EPSTEIN, JEFFREY EPSTEIN Scars, Marks ft Tattoos Not Available Address Information Address Address Source Information Map Link 358 El Brill° Way Source: Dept. of Corrections Palm Beach, FL 33480.4730 Received: 08/27/2009 Show Map Palm Beach COUNTY Type of Address: Permanent Crime Information - Qualifying Offenses Adjudication Court Case Jurisdktion Et Adjudication Crime Description Number State Date procuring a Person finder age of 18 for 0809381 PALM BEACH. FL Guilty/convict 06/30/2008 prostitution: F.S. 796.03 (PRINCIPAL' Victim Information Gender:Female Minor:Yes Arei View Vehicle and Vessel • • Information EFTA00723546 of 7 Case 9:08-cv-80119-RAM Document 433 Entered on FLSD Docket 12/03/2009 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0840380, 0840381, 0840994, 0840993, 08-80811, 08-80893, 0940469, 09-80591, 0940656, 09-80802, 09-81092 OMNIBUS ORDER THIS CAUSE is before the Court on the following motions: (1) Plaintiff' Jane Doe's Motion for Protective Order Barring Second Deposition and for Sanctions (D.E. #378); and, (2) Plaintiff Jane Doe No. 4's Motion for Protective Order Re Second Day of Deposition (D.E. #392). For the following reasons said Motions are granted in part and denied in part in accordance with the terms herein. In this case, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls in question were approximately 16 years of age. As part of this scheme, Epstein, with the I EXHIBIT. EFTA00723547 Case 9:08-cv-80119-KAM Document 433 Entered on FLSD Docket 12/03/2009 Page 2 of 7 help of his assistant allegedly lured economically disadvantaged minor girls to his homes in Palm beach, New York and St. Thomas, with the promise of money in exchange for a massage. Epstein purportedly transformed the massage into a sexual assault. The three-count Complaint alleges sexual assault and battery (Count I), intentional infliction of Count II), and, coercion and enticement to sexual activity in violation of 18 U.S.C. §2422 (Count III). The instant Motions are nearly Identical and seek, as to each respective Plaintiff, Jane Doe in the case of D.E. #378 and Jane Doe 4 in the case of D.E. #392, protection/limitation from having to appear at a second deposition. Jane Doe was deposed on September 20, 2009 for a total of anywhere between just under 7 hours to 8 hours. Jane Doe 4 was deposed on October 27, 2009, and the parties are in agreement that taking into account breaks, the deposition lasted 5 hours and 35 minutes. Plaintiffs contend that under Fed. R. Civ. P. 30(d)(1), S.D. Fla. L.R. 26.1(K), and the Court's Consolidation Order (D.E. #98), all of which limit a deposition of an individual to a single day of seven hours unless leave of Court is granted, it is Defendant's burden to demonstrate why more than seven hours of deposition time is necessary for a particular Plaintiff. According to Plaintiff, Epstein has failed to sustain his burden in this regard and, as such, he should not be able to re-depose Jane Doe at all2, and should only be able to re-depose Jane Doe 4 ' In her Motion, Jane Doe represents that she was deposed for 8 hours. For his part, Defendant Epstein contends in his Response in Opposition that taking into account lunch and other breaks, the actual figure is 6 hours and 50 minutes, which figure he contends was confirmed with the court reporter. The Court finds that whether Jane Doe was deposed for just under 7 hours as Epstein contends, or for 8 hours as Jane Doe alleges, is under the circumstances herein presented, of no consequence. This is based on Plaintiffs' representation that Jane Doe's deposition lasted 8 hours. 2 EFTA00723548 Case 9:08-cv-80119-KAM Document 433 Entered on FLSD Docket 12/03/2009 Page 3 of 7 for an additional 1 hour and 25 minutes, providing Epstein with an aggregate of 7 hours deposition time of Jane Doe 4. Epstein contends the Court's May 14, 2009 Consolidation Order, which provides that "Local Rule 26.1K (limiting deposition time to one day of seven hours) is waived so as to allow each party an adequate opportunity to develop fully the record as it may relate to that party," effectively waives L.R. 26.1K's limitation on the length of a deposition, thereby relieving Epstein from the seven hour deposition limit. The Court disagrees with Epstein's Interpretation of the District Court's Order and finds that Fed.R.Civ.P. 30(d)(1) and S.D.Fla.L.R. 26.1(K) which, absent agreement or court order, presumptively limits depositions to 7 hours, applies in this case. That said, the undersigned finds that Epstein has provided sufficient and reasonable grounds in his Response Memorandum to sustain his burden under the Rules of showing additional time to depose Jane Doe and Jane Doe 4 Is needed to fully and fairly prepare his defense. Plaintiffs are seeking millions of dollars in personal Injury damages for, among other things, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, and invasion of privacy. Epstein's counsel represents he will need an additional 2'% to 3 hours to depose Jane Doe, so that he can cover such topics as background information not disclosed in answers to interrogatories, family background information, details regarding Jane Doe's visits to Epstein's home, Jane Doe's knowledge of other witnesses, school records and medical records, and finally, details regarding her past sexual history, an opportunity he did not have when he began her deposition as the Court had not yet ruled on Epstein's Motion to Compel (D.E. #s 67 & 68), which sought information related to Plaintiffs past 3 EFTA00723549 Case 9:08-cv-80119-KAM Document 433 Entered on FLSD Docket 12/03/2009 Page 4 of 7 sexual history. As for Jane Doe 4, Epstein's counsel represents he will need approximately an additional 4 hours to complete her deposition, owing to her "complicated and eventful past history" including alleged drug use, repeated instances of and arrests. Def's Resp., p. 2. Also, as with Jane Doe, Epstein's counsel claims he needs additional time to depose Jane Doe 4 on details regarding her past sexual history, an opportunity he did not have when he began her deposition as the Court had not yet ruled on Epstein's Motion to Compel (D.E. #s 67 & 68), which sought information related to Plaintiff's past sexual history. All agree that there were instances at Jane Doe 4's initial deposition where she was instructed by her counsel not to answer questions "relatied) to sexual partners' names or sexual positions." Jane Doe 4 Deposition Excerpt, attached as Ex. "B" to Defs Resp., at 5. With these subjects fairly open to inquiry, it is only reasonable that Epstein's counsel will require additional time to depose Jane Doe and Jane Doe 4 on these areas. The Court agrees with Epstein that all of the foregoing issues are directly relevant to Plaintiffs' damage claims and credibility, and to deny him additional time in which to depose these Plaintiffs would be unreasonable under the circumstances and result in prejudice to Epstein by denying him the opportunity to obtain discovery that is central to his defense. See Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D. W.Va. 2009)(granting the defendant an additional one day of 7 hours to depose the plaintiff, reasoning that because the plaintiff provided incomplete written discovery responses, the defendant "did not have full opportunity to examine Mr. Osborne respecting all of the information which might properly be considered in his discovery deposition."). 4 EFTA00723550 Case 9:08-cv-80119-KAM Document 433 Entered on FLSD Docket 12/03/2009 Page 5 of 7 446 page, three-volume Nonetheless, with the Court now having the benefit of the tiffs' Appeal of Magistrate Judge deposition transcript, a copy of which is attached to Plain hours requested by Defendant to Decision (D.E. #430), the Court finds the 4 additional A review of the deposition depose Jane Doe 4 unreasonable under the circumstances. 4 being subjected to repetitive transcript reveals numerous instances of Jane Doe the emotional pain caused by questioning about exceedingly sensitive issues such as treatment the sexual positions she has engaged in, and Epstein's it may be appropriate to ask a of her. To re-phrase Plaintiffs' counsel's words', while er caused her plaintiff in a personal injury case a question about wheth asked over when the essentially identical question is re-phrased and and harassing. Counsel for and over again, the questioning becomes badgering tiffs in these cases covers the Defendant must be mindful that the depositions of the Plain handled correctly may serve to most intimate and private details of their lives and if not needlessly revictimize, embarrass and humiliate them. Plaintiffs in these cases, In order to avoid this result, in all future depositions of the Defendant's counsel is ordered including the re-depositions of Jane Doe and Jane Doe 4, that Defense counsel may not to refrain from repetitive questioning. This does not mean a related nature, but counsel is follow-up on questions asked or ask similar questions of al manner befitting members expected to conduct himself in a responsible and profession sought against the psychological of the Bar and balance the need for the information tions regarding the sensitive trauma that could result from repetitive, humiliating ques ), p.6-7. ' See Plaintiffs' Appeal of Magistrate's Order (D.E. #430 5 EFTA00723551 Case 9:08-cv-80119-KAM Document 433 Entered on FLSD Docket 12/03/2009 Page 6 of 7 issues at play in this case. these Plaintiffs, the Court As for the time permitted defense counsel to re-depose 4 or Jane Doe 4's sexual history finds that any remaining questions regarding Jane Doe the 4 hours requested, and can fairly and reasonably be covered in 2 hours, rather than sexual history can fairly that any remaining questions regarding Jane Doe or Jane Doe's Court's allowance of this and reasonably be covered in the requested 3 hours. The sel as authority to take the additional time should not be construed by defense coun , and in no event will depositions of these Plaintiffs for any longer time than is necessary dance with the above and the Court tolerate questioning of an abusive nature. In accor foregoing, it is hereby n for Protective Order ORDERED AND ADJUDGED that Plaintiff Jane Doe's Motio ); and Plaintiff Jane Doe No. 4's Barring Second Deposition and for Sanctions (D.E. #378 #392) are GRANTED IN Motion for Protective Order Re Second Day of Deposition (D.E. of this Order. Epstein's PART AND DENIED IN PART in accordance with the terms for up to 3 additional hours and counsel is hereby given leave to re-depose Jane Doe ional hours. Counsel for the hereby given leave to re-depose Jane Doe 4 for up to 2 addit to mutual agreement on a date and parties are ordered to immediately confer and come within two (2) weeks from the time in which these depositions can be continued sometime Plaintiffs' request for sanctions is date hereof, unless otherwise agreed to by the parties. denied. bers, at West Palm Beach, DONE AND ORDERED this December 3, 2009, in Cham Florida. 6 EFTA00723552 Page 7 of 7 Entered on FLSD Docket 12/03/2009 Case 9:08-cv-80119-KAM Document 433 4 176.0,t_-,, LINNEA R. JO ON UNITE D STA S MA GISTRATE JUDGE CC: The Honorable Kenneth A. Marra All Counsel of Record 7 EFTA00723553 Jeffrey Epstein From Wikipedia, the free encyclopedia (Redirected from Jeffrey epstein) Jeffrey Epstein (born January 20, 1953 in Coney Island, New York) is an American financier, billionaire and philanthropist. Epstein was raised in Coney Island and attended Lafayette High School in Brooklyn, New York. He attended classes at Cooper Union from 1969 to 1971 and then at the Courant Institute of Mathematical Sciences, leaving without a degree. From 1973 to 1975 he taught calculus and physics at the Dalton School. He then became a trader at Bear Stearns. In 1982 he founded his own financial management firm, J. Epstein and Co. and later called Financial Trust Co., located on his private island in the U.S. Virgin Islands. He reportedly only takes billionaire clients; one client was his mentor and friend Les Wexnerll) who recently hired Dennis Hersch to replace Epstein t21 Since all but one of his clients are anonymous, it has been speculated that Epstein's lavish lifestyle is primarily financed by Wexner.lil Epstein has befriended high profile scientists such as Leonard Susskind, Richard Axel, Gerald Edelman, Murray Gell-Mann, Ben Goertzel, and Marvin Minsky, and politicians including George J. Mitchell and Bill Clinton. In September 2002 he flew Bill Clinton, Kevin Spacey and Chris 'Ricker to Africa in his private Boeing 727, to promote the ex-president's anti-AIDS efforts.l11 Epstein is a friend and supporter of theoretical biologist Martin Nowak. He funded Nowak's research at the institute for Advanced Study in Princetonl il and in 2003 pledged S30 million to Harvard University to fund the .iewly created Program for Evolutionary Dynamics there which Nowak directs.13H the He is a former board member of Rockefeller University, a member of the New York Academy of Sciences, Trilateral Commission, and the Council on Foreign Relations, and a visiting fellow at Harvard University. He has also funded microbiology experiments in Bangladesh, particle physics in South Africa and M-theory in India and was a founding member of the Scholar Rescue Fund. Epstein is a former trustee of the International Institute for Education, the parent organization of the Fulbright Program. He has held conferences on artificial intelligence, cosmology and the origin of life with prominent scientists. In addition to his private island in the Virgin Islands (Little St. James Island), Epstein owns a 50,000-square- foot (4,600 m2) townhouse in Manhattan that was formerly owned by Les Wexner, a villa in Palm Beach, Florida and a fortress on a ranch in Santa Fe, New Mexico.!;! He is often accompanied on his trips and at his mansions by his close friend Ghislaine Maxwell, daughter of the are late British publisher Robert Maxwell° He is also often seen surrounded by young women, some of which employed as his personal assistants.!'! In September 2007 one woman described how she had been hired by Ghislaine Maxwell as a masseuse and assistant to Epstein and had engaged in sexual acts.i° Police investigation In March 2005, a woman contacted Palm Beach police, concerned that her 14-year-old step daughter had been tolested by a wealthy man. The daughter told police that she had been paid $300 for giving a massage to Epstein in his mansion. She had told him that she was 18 years old.l° He had ordered her to take off her clothes; she had undressed but had left on her underwear. During the massage he had masturbated him applied a vibrator to her crotch!~1 EFTA00723554 Police started an 11-month undercover investigation of Epstein, followed by a search of his home. Subsequently they alleged that Epstein had paid several underage girls to perfonn sexual acts on him. Interviews with five alleged victims and 17 witnesses under oath, phone messages, a high school transcript and other items they found in Mr. Epstein's trash and home allegedly show that he knew how young the girls were.ls) A search of Epstein's home found numerous photos of nude young girls throughout the house, some of whom had been iterviewed earlier by the police.n He had set up a system of young women recruiting other women for his massage services, paying $200 for each referrals) Two housekeepers stated to the police that Epstein would receive two to three massages per day whenever he stayed in Palm Beach.171 In May 2006, Palm Beach police filed a probable cause affidavit saying that Epstein should be charged with four counts of unlawful sex with minors and one molestation coup irl iew, one of the girls related that she repeatedly had lesbian sex with Epstein's friend in his presence; she stated he "had purchased her from her slave."t91 family in Yugoslavia. Epstein bragged he brought her into the United States to be his Yugoslavian sex His team of lawyers included Gerald B. Lefcourt, Alan Dershowitz and later also Kenneth Starr?) They stated that Epstein never knew of the under-age status of his masseuses, which was confirmed by subjecting him to a lie detector test.") They also questioned the credibility of the teenage accusers, based in part on their MySpace investigators?? t1 postings and information obtained by private Instead of following the recommendation of the police, the prosecutors considered the evidence weak") and presented it to a grand jury, an uncommon procedure in non-capital cases. The grand jury returned only a single prostitution,I123 to wm •• ch Epstein pleaded not guilty in August 2006.1" ) The Palm charge of felony solicitation of Beach police chief, angered about this minor charge and suspecting preferential treatment of the wealthy, complained to the state attorney and then turned the case over to the FB1.151 In December 2007, it was reported that Epstein was involved in plea negotiations and was expected to plead guilty to a charge of soliciting prostitution and spend about 18 months in jail?) A guilty plea was finally wonted on lune 30, 2008. After the accusations became public, several parties returned donations they had received from Epstein, Harvard including Eliot L. Spitzer, Mark A. Green, Bill Richardson,141 and the Palm Beach police department's) announced that it would not return any money?) Civil lawsuits alleging child molestation, assault In a related case, Epstein was sued in October 2007 by Maximilia Cordero, a male-to-female transgender model, who claims Epstein forced her into a sexual relationship at the age of 16.1131 On February 6, 2008, an anonymous Virginia woman filed a $50 million civil lawsuitt141 in federal court against Epstein, alleging that when she was a 16-year-old minor in 2004-2005, she was "recruited to give Epstein a massage." After being brought to his Palm Beach mansion, she claims that he exposed himself and sexually assaulted her, and paid her $200 immediately afterward.112) A similar $50 million suit was filed by a different woman in March 2008 who was represented by the same lawyer-Vs) References . A it c Landon Thomas Jr. (2002-10-28). "Jeffrey Epstein: international Money Man of Mystery (http://nymag.com/nytnetroinews/peoplein_79120 ". New York http://nymag.cominymetto/news/people/n_7912/. 2. A "IPMorgan's Herscb succeeds colorful money manager (http://blogs.reuters.com/reuters- dealzone/2008/02/11/jpmorgans-hersch-succeeds-colorful-money-manager0 ". Reuters. Thomson Reuters. 2008-02- 11. http://blogsseuters.conteuters-dealzone/2008/02/11/jpmorgans-hersch-succeeds-colorful-money-managert 3. A Financier pledges $30 million to support Harvard researcher, The Associated Press, 7 February 2003 4. A 6 c "Harvard to Keep Epstein Gift (http://www.thecrimson.com/article.aspx7refn514187) ". The Harvard Crimson (Harvard University). 2006-09-13.. http://www.thecrimson.com/article.aspx?ref-.514187. Retrieved 2007-09-13. EFTA00723555 5. Agree' if "The Fantasist (http://nymag.cotn/news/features/418260 ". New York 2007-12-10. http://nymag.com/newsleatures/41826/. 6. A a "Prince Andrew's friend, Ghislaine Maxwell, some underage girls and a very disturbing story (http://www.mailonsunday.co.uk/pages/live/femail/article.html?in_article_id•4834018dn_page_id=1879) ", The Mail On Sunday, 23 September 2007 7. AS e I Palm Beach police probable cause affidavit against Jeffrey Epstein (hup://www.thesmoldnggun.com/archive/0726062epstein1 limn) , The Smoking Gun 8. A e "Jeffrey Epstein craved big homes, elite friends - and, investigators say, underage girls (http://www.palrobeachpost.com/localnews/content/localnews/epaper/2006/08/14hrilaFYSTEIN 0814.html) 'I. Palm Beach Post 2006-08-14. hup://www.palmbeachpost.comllocalnews/conteat/local news/epaper/D06/08/141m1a_EPSTEIN 0814.html. 9. A 'Exclusive: Jeffrey Epstein's Sex Slave (http://gawkercomlnews/crime/exclusive-jeffrey-epsteins-sex-slave- 190625.php) ". Gawker.com. Gawker Media. 2006-07-28. http://pwker.com/newskrime/exclusive-jeffrey-epsteins- sex-slave-190625.php. Retrieved 2008-02-24. 6 "COPS' FLOPS LETTING MOGUL GET OFF EASY A' 10. (hur//www.nypostcom/seven/11122007/news/nationathews/cops_flops_letting_mogul_get_off easy_303421.htm) ". New York Post. 2007-11-12. http://www.nypostcom/seven/11122007/news/nationalnews/cops_flops_letting_mogul_get_off easy_303421.htm. 11. A "Questions of Preferential Treatment Are Raised in Florida Sex Case (btp://vAvw.nytiniescom/2006/09/03/us/03epstein.html) ". The New York Times. 2006-09-03. hup://www.nytimes.com/2006/09/03/us/03epstein.html. 12. A' 6 Keller, Larry (2008-02-06). "Second teen-sex suit seeks $50 million from Jeffrey Epstein (hup://www.palmbeachpost.com/localnews/content/local news/epaper/2008/02/06/0206EPSTEN.hunfi ". Palm Beach Post http://www.palmbeachpostcom/localnews/content/local_news/epaper/2008/02/06/0206F-PSTEIN.html. 13. A "GENDER-BEND SHOCKER (htrp://www.nypost.com/seven/10232007/newsfregionalnewrigender_bend_shocker.htm) ". New York Post. 2007-10- 23. http://www.nypost.corn/seven/10232007/news/regionalnews/gender_bend_shockerltm. 14. A 'Billionaire Faces $50M Sexual Assault Lawsuit (littp://news.findlaw.com/hdocs/docs/pi/doeepstein20608cmp.html) ". FindLaw. 2008.02-06. http://news.fincUaw.coroThdocs/docs/pi/doeepstein20608cmp.htinl. 15. A Keller, Lany (2008-03-05). "Third alleged victim files sex suit against Jeffrey Epstein (http://www.palmbeachpost.com/localnewskontent/local news/epaper/2008/03/05/0305epstein.html) ". Palm Beach Post. hup://www.palmbeachpost.comllocalnewskontent/local_news/epaper/2008/03/05/0305epstein.html. Retrieved from "http://en.wikipedia.org/wildileffrey_Epstein" Categories: 1953 births I Living people I American businesspeople I American philanthropists I American billionaires I American Jews I Harvard University people I People from Brooklyn I The Cooper Union alumni I American sex offenders e This page was last modified on 1 January 2010 at 07:50. ■ Text is available under the Creative Commons Attribution-ShareAlike License; additional terms may apply. See Terms of Use for details. Wilcipedia® is a registered trademark of the Wildmedia Foundation, Inc., a non-profit organization. ▪ Contact us EFTA00723556 Web injeggi Videos Mans News Shopping Gmail more spencer.kuvin@gmail.com I Web History I Settings v I Sion ou, Gocsie :Jeffrey epstein" Search 1 My... Search Web Show options,. Results 1- 10 of about 38,600 for "Jeffrey epstein". (031 seconds) Jeffrey Epstein - Wikipedia, the free encyclopedia Jeffrey Epstein (born January 20, 1953 in Coney Island, New York) is an American financier, billionaire and philanthropist and convicted chid sex offender.... en.wikipedia.orghviki/Jeffrey_Epstein - Cached - Similar - Jeffrey Epstein's "Sweetheart" Plea Deal, Embarrassing Deposition ... Sep 17, 2009 ... UPDATE 9/18: (Scroll down for video of Epstein's embarrassing deposition.) Epstein's secret plea deal on his original criminal teenage ... VAvw.huffingtonpost.com/.../egg-shaped-penis-jeffrey_n_290464.html - Cached - Jeffrey Epstein: International Moneyman of Mystery He's pals with a passel of Nobel Prize—winning scientists, CEOs like Leslie Wexner of the Limited, socialite Ghislaine Maxwell, even Donald Trump. nyrnag.com/nymetro/news/peopleM_7912/- Cached - Similar - Video: Lawyer Asks Jeffrey Epstein If His Wang Is Indeed 'Eoq Sep 17, 2009 ... Video: Lawyer Asks Jeffrey Epstein If His Wang is Indeed 'Egg-Shaped' ... this video of accused sex offender Jeffrey Epstein being asked, ... nymag.com/daily/intel/2009/..Jvideo_lawyer_asks_epstein_if h.Mml - Cached - Image results for leffrev epstein" - Report imams Jeffrey Epstein - West Palm Beach & Treasure Coast area breaking ... Feb 17, 2009 ... Judge: Palm Beach sex offender Jeffrey Epstein agreement to remain sealed ... Billionaire financier Jeffrey Epstein has been sentenced to 18 ... www.palmbeachpostcom/localnews/..J0217epstein.html - Cached - Similar - Jeffrey Epstein Kept Company in Jail By His Alleged Lesbian Sex ... Jul 22, 2009 ... Billionaire convicted sex offender Jeffery Epstein Is now a free man. He did his 12 months for hiring underage prostitutes, and left Jail... gawker.com/. ./jeffrey-epsteln-kept-company-in-jail-by-his-alleged-lesbian-sex-slave - Jeffrey Epstein To Roam Free at First Liqht - leffrey epstein - Gawker free Jul 21, 2009 ... Billionaire teen-girl-massage aficionado Jeffrey Epstein is won to be a man! As dawn breaks on Wednesday, the gates of the Palm Beach ... gawker.com/5319678/Jeffrey-epstein-to-roam-free-at-first-light - Show more results from clawker,com EXCLUSIVE: Jeffrey Epstein To Be Released From Prison Early ... Jun 19, 2009 ... Jeffrey Epstein, the Florida money manager who once roamed in the same social circle as Bill Clinton, Prince Andrew and other high profile ... www.radaronline.com/.../exclusive-Jeffrey-epstein-be-released-prison-eady - Cached - Similar - Citvfile: Jeffrey Epstein Goes Free, Reunites With His 'Sex Slave' EFTA00723557 Jul 22, 2009 ... Guess who's been released from prison? That would be Jeffrey Epstein. the secretive money manager who pleaded guilty in 2007 to soliciting ... cityfile.com/dailyfile/6615 - Cached - Is Jeff Epstein Also Running A Ponzi Scheme? Jul 22, 2009 ... Jeffrey epstein Palm Beach billionaire Jeffrey Epstein left the Palm Beach County ... Jaded Billionaire Jeffrey Epstein Eating Moon Pies, -. www.businessinsider.cordis-convicted-sex-offender-jeff-epstein-running-a-ponzi-scheme-2009 -7-Cached- Searches related to: "Jeffrey epstein" jeffrey epstein palm jeffrey epstein ahislaine Jeffrey epstein bear j ffrev epstein beach maxwell stearns Jeffrey epstein miami I 2 2 4 5 6 7 8 9 js Next Personalized based on your web history. More details Add a result - See all my SearchWiki notes - See all notes forihis SearchWiki - Learn more ("jeffrey epstein" Search I al Search within results - Lanaume Tools - Search Help - Dissatisfied? Help us improve - Try Goode Experiment Gooale Home - Advertising Programs - Business Solutions - Privacy -About Goodie EFTA00723558 ORM 11:XAM DIWO N•MT D1I CHM ARM, - A rawer Ne. York Pea BILLIONAIRE'S DEFENSE ARMY New York Post • New York. N.Y. Date: Aug 9,7006 Sian Page: 011 Section: Page Six Ted Word Camp 117 Document Text BLLIONNRE Jeffrey Epstein has hind a platoon of Now to make electricity -bull lawyers and publicists b rebut occusations p4 Freak of nature has electric CO's Executives that he regularly enjoyed nude massages and sex shakin' in they boots vitt underage gins. An ii -month pcotse by Florida %wow Powc, 411,,ent.com prosecutors resulted In just one charge against Epstein - that he &arched happyendings' tom adult masseuses al his Palm Beach estate. Now the tilyfljs for newspaper fanner partner of kbrt Zuckerman in Radar magazine Search multiple engines el once Is repped by* Dream Team a tamers -Nan archives Derstweritz.Roylilackelaa Goldberger and Gerald wontwobainklegtom Lelcoun- plus p.r. gurus Howard Rubenstein and Dan teems. Goldberger is discredit/1g some of Epstain's accusers as untrustworby drug-abusers end loaf dultifildsaftstress Wnet concerns you the most? Share your opinion cops as childish' He toid the Palm Beach Post. 'These women ore liars. W010 eitteblished that' el Harry Reid. HsayRneo co& Reproduced Mal ponnition of the cogyhrt owls. FOAM Rhpe0Ou0011 Or chtbeollon tspeOhitstog felhoul peinliaion. Abstract (Document Summery) so rebut accus °lions fhal he BILLIONAIRE Jeffrey Epstein has hired a platoon of 04ml' lawyers ens pubiasts regillorlyfirljOygg nude massages and &emir, endorsor, tallS. oorrnfafor. RerOduCad Mph perinpoon of the oopynghi pint. Funny reproducinon a etaisteeen is aerosolise what CHM •AltialahI Pet Pt rinfinarthMeltwal anhirTa-tisilM:7070:.rentP0d1=10937076.entestteSszn.tesfuer•OnikacnIWONATIE trS•DEP EFTA00723559 SIM »MIN Oreer anst4. or Po+ tv." oaro. 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RealfskS estatteada, Shwpkva Hale •ir-SWO;fraiOrtnt SW Web mane tlt •• sienna' Spout ~Iron Crlsorilet Orb: Efet ht. acme: rate« v:ew, Scrum: ordom Stgam I Startslintaamb HE WAS OVER 50. AND THEY WERE GIRLS BYLINE Erie Game DATE: Meet 1, 2006 PUBLICATION: Pam Beam Post, Ike (FL) EDIDON: MAL SECTION OPIWY4 PAGE: 20A tad, V ew ~rim slab Pam Bach Nita soy a pentbse tom resident :need to Ns home mid pod kr am eats ttra In werenl aria the sotablion page warns:~ Epstein men teel !ONO Whale& Ott. sdistIng to pacts macs they Hs was trend And they view aids 44 15 16 17-yeakaa girls. 1St Shedd tea te so/wetted - tM dItletenco Stade artstetnon end ped,:o~ Ennis Nebo Vat 1k. Ewan, Wm vas ~pi tem month bya yard Myatt one bray cam d ethetolkn cf probblIon SS not ban cadged, b NW, actet, hake glartastilY ~SS Ishii ~Ai sett eats viii • reha end lewd ere, eischkus mdestatnn CoWctler, d tames aminst mram ,.ala mean steeper penalties than Ow mailmen bayed Person ken IN. E-IWW. Wes understand to weak ete prey on pts. ~06 G. the Dade Win ce Merry sokraticit P Sus "add kly tirye mower • by sold eta Prosecubs etc rOt pnia) ctiVaste Karen Its Emhart reacted the ape et Me Scans lassos° Mk 'muffled ss tide net os ~ma OA as sterntraina. triliusborthy. MusD prIldpents. 'Me peaurnakn le ~to and debase looney Mt. Epsttin.e 53-yiewiti lanittal WWII manager dank Wed Hatted ta ~set Agn DendatrwM Jack addbertmr. ha Coded knookg has eV lb Ørk -re But poles inkreests arth keedepol Nelms md 17 varecess tsar park at welt as gho6e seinfeal.•MM Wool tiareal( end Obi Aetna Pot police burd kern one? Mr. Ebtekk oath end 7,234w~ was hems prole Nara that ho knew the pans bra kedged. to Ns One gel couldn't them ket WWI Mr. Epstein sacked beast she he soccer. Malte time, Mr. Epstein bed vat tor better' masonDame Pe pit Ss toad real ~In de« 16.yoeretd see ads to Wiry atit Su,Mossy Sew Nilarv tektite% otelde whether ha Wow ire deepen - ladero e Mr Eggers ham to "sod' el Odambre 2004 Met bone asked Mtatter who noble to make shanty b Cietalmes Des? on apesete. end ta snar their Pa:~ pea lane W0;0 to the dead. Ati Cershowitz padded abed the rift In characur. W. Dershosts ponied de lo poboAcia lb: some a the (enryen hod hake on myepace ØØ ~Lyn ard eldtatl to edda Ards» ro charges «bass ~yen% tow been Ides ote pima det keel one lathe teenage bairns ~trite &tieing Slaved end labbated bl him men. Poke debunked Mot their wind« ems fesiateted lo Na NW, ~gates. W. Odcbsr eased knotting mytheg axe k. an Poked We ride fri thee am" Mot it. ate ettommon eke oherd W. Epstein • den sat tat void 'WC rWeed Sn. taatettOttlae ese lam darnels& te ate SW/ sala ro aaana Neat sa tak Inked W. Widen spokesman, saw Etboneten. why the we vas ~sod to • rend hey uredd or Mr. Epstein herd • abaft teen and end tackle o Vtd belie a jay. Are ~Ialt the ticket' creSettry be a teed to deternere ~Cher *EleY new errand. hol DorkTI Wet el. et Lor. Canker, tote tee Pda Beash Pat d Mr. Eaten, deeded gib ere to tie hide') ta.~ st.y.ciry cowipunnen".~..-, 10” reFAøneatntØYNM1suq,.Nl.r.'¢nasY.m[O.3L>IDW- EFTA00723561 10109 1 t>e AN 090,9• tflWa It Par Ian •4499 art IR la move -Y IIVl taltKa API* el Espottally. Pits Mod Lb. Mattardeon to elpat Whyshouldn't the eta& look r case era ISMS then we low Minds of Neste. - one lot te went/ era ono Pt Us test ot us? sake ca Mt. fainscedsOn sal0 he watt not mermen, on me ant became it a odic. tat at She tour part be etre& be the Power to Pat rola. ci 'pbtlerepthicat Clebae: 'Wbettssr MUM tuts a Mitten' Vandal et tatted tsPoss the away come, be yet' issue tat was debated Bit it this case. he sod legattoss el the btalerycaoltootys. Pe Ccedome Yak be the salt. eery In page bee &baba to out Mee Debt Ihe case ten to Ma pond jay • hlie easte.tils rot tea itetkris' cmdealy but the state secaters Ow dawn telesrotiro m EMIL Cotner is an etaketel war er The PIM Beam Poet Mn awns: address is boa crantergoMeitet.co Featured Jobs IIII••••••01 puled SEiVabrnapeettut HOC SERVICE TECAMCW4 4SER. 09104,1.... eikgkgre-WAMEM SALES REP. Well estekatabel kigort:-.AMEIM alEOCAL /GNAW MOM/CMG .CLMIZAL • - SOPRABONIZITOPart POND SMOKER TRANCE Cant S25Cit• orsoas Mitt. AO hob" o Job, (.m* 1020013, lie PainBaia Pot Al IWIS merved fly testPaktchPastoorit youarctic the tam: of ow %tor *put P}ne re:s4 k. Cd2319ahattiSIM I rthIlareb I Cbc_ricom CA*F7,;17C Slkwnlijottu:00940)1041.114113.119029315,10:9009910999. > 0' 3 raor...1.99c.t.w9t.orr..999,69•99.94,0,nia.no 99-69,09-:_00999•9111%.19114(.0,120.090an• .0.199.946.113onts•414.0.999., 194, EFTA00723562 10RM11:75An MASSAGE KAV EM OUT OF POISON • sittlyer New Yet Pon MASSAGE MAVEN OUT OF PRISON New York Pos; • Ne... Yon. N.Y. Paler. Monyncu.s Date: Jul 23.2009 Sten Page: 42 Section: Page Sac Test Word Count 303 Document Text JEFFREY Epstein is a free man. Yesterday. the httersomser Archive massage.loWng dlfonaire financier was released six Search Full-TS Newspapers Find Exensive months early from his 18-month prison sentence in Coverage 1800.2000 Florida because he's cooperating with federal twia•Nevienlieltuf con" prosecutors. Epstein, who pleaded guilty b procuring teenage girls for prosetuton, Is helping the lefts prosecute Ralph Ciotti and Matthew Tannin, the Beer How to make electricity Stearns hedge hind managers who allegedly took him Freak of nature has electric co's Executives for 567 million. Ck46 and Tannin are set to go on vial shakin' in their boots In Brooklyn federal coun on Sept 28 on charges of .w.Pcompriltent.COM misleading 'mantas in their subprime mortgage imostrnent fund. which went bust last year. Epstein itamathaliketty.. was given work teleette from his down at the Palm Beach Countyshades 17-erne.9676ed stockade. On Health Reform. What concerns you most about -He's been Wang the ogees of his law)er,Jack the current system? Goldberger, 12 hours a day, six dos a week? said lontecia commorormaiNer One source. 'He wet :Weans effrYwoOfirit on his Patsy Goo& penonal dimity, but he was really working with the Andrew, has a mansion in Palm feds: Epstein. 56, who used to hobnob wan the bites of Bill Clinton end Prince he Beach,. renal in Santa Fe, the largest private house in Manhattan and his own whole Island in the Bahamas Jeffs: Imestigetne repaid John Connolly told Page Si that Epstein was so happywith Goldberger, who calls 'St is negotiated his plea deal, he go* the lawyer a branding.* black BMW. A friend of Epstein told Pete Sic sifJciffrey the helping the gmemment, the ID of the gowimmen1just went up.' As Epstein prepared to sleep in his own bed, Jail friend said, 'This is a difficult lime br him. He's looking foi a new be inning.' But. he sell has his old friends. retards indicate he was %ailed more then 67 times bymodel the 'eSSistarlr who police say wrangled teen masseuses for Epstein and joined M the sordid sex play. RoorOduced with pernision of the COOStif Owner. Fisitnet renduCtutin p WItortkon ISfintrbitnied wtiOul P000ntbdin• Abstract (Document Summary) early JEFFREYEpstein te e tee man. Yesthrday, the masssge-loing billionaire 'Bander wen released sixmean Iron his 15-month prison sentence to Florida because he's cooperating with federal prosecutors. Epstein. who pleaded guiltytO procuring teenage gins for priasalution. IS helping the lees prosecute Ralph Clog and libtflew Tannin, the Bear Steams hedge fund managers who allegedlytook him for 567 maton. Ciotti end Tannin are set to go on vial in Brooldyn federal own en Sept.28 on charges of misleading 'mission In their subprtme mortgage hwastment fund, which went Dustiest year. bermisson RstiroSuord with porinistion of lb. combed °stmt. finnar itproductUen oi distribution h prohibbed *trout 5 togs 1011 hnOcAttissOfttriststs•ssentutoonccen.V17996629311ounriov179736. Yon•Sormaitistutsitude•latest•onSTAGT•PSTT *Out •O• • tesSONW• EFTA00723563 The Poini Beach Po:ii Click he for spedat coupons an e saving's " hi . A SERVICES on pot pi °ducts for.? iimktiocirctfrie:opfr Suburb* Renew :CMS I AUTOS I REAL ESTATE I CLASSIFIEDS I HEALTH I MACE Aso AO HOSE I NEWS I WEATHER SPORTS I MONEY OBITUARIES I OPNI0N LIVING I ENTERTAINMENT I PHOTOS I VIDEOS SERVICES I , Semen Services L We Saga by WACO' . it warm* Palm Beach sex offender's secret plea deal: Possible co-conspirators not charged, presses cirnzia victims to settle civil suits A new treatment option for oath By SUSAN SPENCER-WENDEL patients with moderaely to severely active rheumatoid c4ireis (RAI Pam Beach Pool Ste Writer Friday, seram bet 16, 2039 WEST PALM BEACH— Sanaa anancter sea offender Jetty Epstein's Secret norsrostashaagreeMent he iumeenoit Gaol muck an Mara isrose0AorS was isrmaled Friday, Panne me firm mac look at to deal Ealing Nrbecnirired ni.WhiPpundro in riztitxth lake, legal oculist: brokered on Ns beat. Se^aa , Infeepan °wow, suerxing tsisencreesis (Mane otleaken amend to vinnell, fon or bete& that hem Aocoreng the *raiment. me Federal Bureau of invesbason and the US. Naeineys Office Invosigated Epstein by mite leder amis. Wading rostation, some punishable bye Marian of 10 year Cr 10 Men Fawn MOST POPULAR derintalFS L1394.50 stow:sc.: But federal grostra4ors barked dower and agreed to atoll wend jay sapoemas. x Eileen plead gay to Mich Protaiubonreated felonies in stile CourL which he uliimaely dd. He received an lberiOrel to SentereX. Of tee teen wan; 20 yeas to do Ns.' alleged lobe says he Serra 13. after shooing in Amite A former *anal rounder of 15 yeas, Mar Johnson of Stuart said Foe disparity in the potently sertenteS eras neat smond.PymeIaidy hens ear inuSua. Ateited *Ws fl ew: Sat appeal: dive, deal ehOdliaiiiirge any of EpSteln% octane co-COnWelitOrt -- Fiala 37. Reba Bub 10. Tebow lads UF in Ns Ha Wave game The fereeinent wet fa:Meted n pen by New YOM htWeyeeige arrow detest Mahn Gerald Lefown. Swung Mars siieneect forever MThentiagang man* On its list drat in Smoterrner 2007. II required Met Epstein My WI attorney - lapped by the U.S. Mtomeys Cam and appeoved by feStetri -10 teteesent some Of ore WOOMS In Chef suits hey hid fed Spinet E.pstein. That metway rominent Men; lawyer Bob Jester:berg. Fanner prosecutor Jansen sail no has nave seen a provision like that betas. But an SeklenOurn Ic the ogramern signed to loeleMng month Muck Essterrs duty to pay Jefetstrato y he end the eCtIrre did nor accept a sediment and instal armed Iligabon. The Weenie, signed by Asuman' U.S. Attorney Mans Wet nit. does not earesem stet whetkei any widen were contacted Ce consulbad bobre he deal sine wade. Me Atorhey Brad edwardC of Fort Liudendale, wee represerds three of Me young women. bteeveS met none of between 30 at 40 weer eeltiet1 as eiCtiMS In MI 100We iftreStiforten Wee foe of the deal. Edwards said Ms dent& went eel rearing letters in Ma mail months Aeneas leOriO en U.S. Always Me nearing them Eater nerd be preiroseed. laver consulting me Hann is teObLety Ihe most Outeeecon aspect of EOYMTOS sale. It NAN men mar someone vas money can buy tie hey or of anytting its outrageous and embarrassing fa UMW States Attorneys cence and Ow State Ammer Cake' Epstein now barn many OW Mernsits aid by the saran, who ere represented bye rale, attorneys. In matte. the and taps lined ate the same: Med Epstein had a gsbeeceari for teenage got, identified poor. venerabre ones sarcase bred van sole Lad them to Ns hams a other young women. The teens describe asoandlre a ohotOgnOM of young VS and b the aid room Mere Epstein woad ICCeer in 0 email Mal. Former Chap Judge ea Berger. et* represents one of the victims. and The Palm beach Post sought re unseseng of the threement. Berger mews to it as • -tester doh r 'Why was It so imminent for IN grnwretent kr make Ms der?' Berger asked thektally. We have not yet had were sold down re Mier MOW ett0Olateh by any pubic arca it 10 .m1 n was made trod why the viclim's erne iedeal prosecutor Ryon McCabe Mooted Ow agreement as ^very unortodox." Such areemants. he said. are usually reserved for carciaans. not incerklues. 'me veg. very red, eve never stria Of Mold Of the procedure the was at up here' Mid McCabe. MN his is ovenware iv any Easton Miran and is now a seculbes togabon *Donley. lids temente/ means federal prosecution because he can sited to coy that many Illity•fitohePth060 tams review thole ... H a Derain has ria money he cairn be able to siraok a deal Se ass and avid federal The bec-mom der with terra prosecutors st the more interesting in bre of the legal twaymegnis ere have werkeeffor Egelea, incluong Harvard re010350- Alan DennorAtz and Marren Slew of arson brosettrmare bene LefOttal is a oast presider* of Pie National Anecialson of O'Mara Defense Lawyers Epssevia local defense teensy. Jodi Cattergor. awed a Statei*nt Friday saying ne had beau Me Wean of the UMW apreement to protect the third patties named Mere. 'Mr. Epstein ha:. eXy abided by all of its tome and contacted. He 1S looking fewart to Wang the Oates period in ha Me behind an. He Is continua-if) his long sundry history of science teneommor.? Epstein ended up macaw federal thersed and pealed guilty in tune court to Naomi latecason a Putakiscri an procuring a person under the apt of 18 for proslesten. In July 2038. he was sentenced to 18 motive nod. end law allowed out a to sb (eye a was on yak Mesa. for EPSIon let Tie predate Juts, 2009 emir sating not Quite 13 months of ore sentence. twang earned pan One good betiovisr EFTA00723564 New Yolk magarne dubbed Palm land. POGO began Iwesagaring tie 'flternational ~erten of mystery.' as Ike hod given Speller $ naked matuage at him. nu they received • completes Yr a rebore ot • I eipseieted gid who no home on rue Irenwidastal *town. who Ida stones of Police sought and fond m p0Or raglitormods a variety of lip. vol. mOW4like young her, TM'S walked away we WAWA begin recalling. then going to Epsbeink home and minstiong area stimulating $200 end 11.000. th thereehler /Atha!, Reiter saying In a May The kwasbg•kon triggered NwStels berreeen police and preiseculces, w loosed MX Ise to Inn-State Niamey Betty Knschee te l the order proses-ow should disqualify 1 corona to end yew °Ikea tre•Wort of this. Cases /14 1IY Reiter 111041 140 then Wad fed and got the keener entStrIsan M1 tinde0 es me sealed dee. Refer told 'The Wavy Epstein Matter was n experience or what a rmnyerviOnidorter defense can accontatein.' 0w Palm Seed Dane Henn upon his raWarnant. Flight to Welt Paw BO•ch Most Pelm Swett Jobs Holiday Inn Palm &what weer Prim Ewen Jets Pang Pre NWT Rend revrtwi for Ina (mein. Win drociram, Save Up to 65% en Fires to West Palm Vatla-te.C4feadiCh urn Senn St. Tim You Can yemmlnelaaroaccm emoicriziotentatenes coo Fes lay 'Yanta SECTIONS MARKETPLACE AFFIUATED SITES 1EL t VS WRAY YOU THINK OR PERO US A TIP Real Estate I Nato Nana tAlleMialniereclybown lestuooll Send us your suggeSlions abed els one. 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AtTides by: Jobs Autos Real Estate Classifieds Shoppirg Health 4ruirotal rio gcn a Site C Web l) Home News Weather Sports business °albumin Opinion Living Entensineinem Photos Video Wogs Options: Sonficos Results list Start a New Search STUART ATTORNEY GARY WON'T BE CHARGED IN ALLEGED RAPE BYLINE: JANE MUSGRAVE, Palm Beach Post Staff Writer DATE: December 2, 2007 PUBLICATION: Palm Beech Post The (FL) EDITION: MARTIN-ST LICE SECTION: LOCAL PAGE: 1C MEMO: Ran ec editions Famed Stuart attorney Nellie Gary won't be charged in connection with a sexual liaison with a former employee of his high-powered law firm. Assistant State Ationtly Erin lerloirood confirmed late Saturday tat Stuart police had dazed their irweStigittiOn into the 25-year-old St Lucie Corny wcenan's allegations that Gary raped her in a loom et the Best Western motel in August. "Insufficient evidence' Kirkwood said simply when asked why the 60-yearold lawyer wont be charged. Defense attorney Richard '<ditty, who hes been helping the renowned civil litigator navigate the criminal pellet system, said his them la relieved but not surprised by the decision. "My animal prosecution of the case would have been laughable: Kibbey sad. Attorney Linda esoottiarco, virus is representing the woman in a civil lawsuit she iced against Gary and his law bin, said she needed more Information about why prosioAxs opted riot to Charge the sedstrteloirned "Giant Killer' before commenting on their decision. She is scheduled to meet with them Monday. 'we're obvious's, des/emitted; Cipoblanso said. "But we have flit confidence in our clients Arthough the wornen's identity Ms not been revealed because of the nature of the allegations, Capoblenco said the woman is anxious to talk pubrigly in hopes other women who might have had similar exponent:in wilt have the strength to come forward. Both sides epee that the two had sex. Gary. who's married with four adult children and two young ctildren who were born cut of wedlock. ins/else was consensual. The mined woman Mims he forced himself on her after summoning her to the motel room th downtown Stuart. Both aides oleo agree that Use battle is far from over. Even before the Criminal twestigation was made pubic, Gary filed suit against the woman, her husband and one of their fr erida. clothing they trumped up the rape allegation to extort $1/1 Malkin to 325 Mike, from him. Tea is nothing but a major shakedown for money.' Michael Pike, one o/ Gaya attorneys. has said. The women responded by filing a cke lawsuit against him had his taw firm. The suit includes vivid details of whet she claims was the fateful meeting. In the lawsuit, she claims Gary lured her to the hotel room, and when she emerged from to bathroom, he was naked. He grabbed her, threw her on the bed and raped her. she datums in the lawsuit. In his lawsue. Gary claims the two had consensual sex on several occasions after she came to hint saying she had information about vanciam at his taw office. The two lawsuits spawned a third. Maurice Sharer. a friend of the woman, wed Gary after the attorney claimed he was involved in the extortion plot. In his defamation suit, Shade accuses Gary of having 'a reputation for infidelity, promiscuity and sexually aggressive behavior.' Kibbey said Gary cooperated with police. The poldicaty salve chairman of the Black Family Channel. who hes won lthirson against corporate giants such es Coca-Cola and Moose& met with police without an attorney. He passed two polygraph tests. Kibbey said. The mess has put a strain on Gary and his famiry. Kibbey said. Capobianoo. meanwhile, said the truth eventually will come out in court "We're going forward with the WI lawsuit no matter what' she said. teals Heimeniks contributed to this story. muetration: PHOTO (BSW) Milo Gary (mug) Comer K) Tad' •Mni Sewn Menissigen, EFTA00723566 PahnBeachPostcom I Archives Ho Mai/Sea?. RV. . tzeest wextrer!" asAAA 'P'n'Lateapra • • • ,, orelferetta Wardt . — • 'Attila gIchttr,-;:i:44E-stcv -- Jobs Autos Real Eels Classifieds Shopping Health hempat ne iatis.maliker seancoDV a site r web Nome News Weather Sports Business Obituaries Opinion Living Emarlainment Photos Video Siege OptiMIS: SorvoC46 Rasa ag I Start a New Search WILLIE GARY LAWYERS FILE MOTION WITH X-RATED DVDS BYLINE: DAPHNE CURET and JOSE LAMBIET, Palm Beach Post Staff Writers DATE: July 29, 2008 PUBLICATION: Palm Beech Post The (FL) EDITION: FINAL SECTION: LOCAL PAGE: 38 MEMO: Ran al editions. The attorneys for Swan Wryer Wale Gary filed into court records Monday a pair of explick DVDs along with a motion to dismiss a civil sari 8_..4.xsIng him Q. sexual *SUMS The homemede DVDs showed Ganes single scan son. Kenny, having sex with Jilhan Need. who has accused Willie Gary of rape. The Second DVD was recorded on July 21, a week after Nedd and the elder Gary had sex in one of flee encounters Nedd tlearu was coerced, said West Palm Beach lawyer Michael Pike. the claim she was assaulted by the father. yet a week tater. she's making an amateur sex video with the son,' Pike sat. Also filed In a Martin County court were witless accounts that on July 12, one day before the second encounter. Nedd bragged at a bar that she was hasp Gays mistress: Police investigated but never hied charges Nedd contends that Gary coerced her into having sex July 13 so he wouldn't pursue vandalism charges against her husband, according 00 court records. Nedd's attorney. Linda Capobianco. said the OVDs and other exhbits were erner irrelevant to the case or inadmissitre in court. 'This is a blatant attempt on their part to start the focus from The actual facts of Ihe case: Capoltiancc said. Illustration: PHOTO (88W) Michael Plke Mac) COOrr (C) Wee P.On ere 51Nenoven, '1. Tips To ',Sexy Stomach' I Cut Downs Ibs of Stomach Fat Per Week By0beyirit These atasy Tips Featured Jobs WAITERS/WAITRESS% RESTAURANT STK, Bose West le a 8888LEDSULEDALSEEMAMI PARALEGAL I LEGAL ASSISTANT. FT .._. CATEIMIGMARSETING DIRECTOR CATERINGOAARKETING DIRECTOR.__. EFTA00723567 PalmBeadilbsicom MArchives Jobs Autos Real Estate Classifieds Shopping Health 4. 120n4,oi at it N Site r Webp 0 Home Nen Weather Sports Business Obituaries Opinion Living Entenelamem Photos video Slogs Options: SefV,C02 ReSURS list :Start a New Search JUDGE ORDERS FEUDING EYE DOCTORS TO AVOID EACH OTHER BYLINE: Pal Moore Palm Beach Post Staff Venter DATE: June 22, 1999 PUBLICATION: The Pain Beach Post EDITION: MARTIN-ST. LUCIE SECTION: LOCAL PAGE: I B MEMO: Ran all editions A Judge Monday ordered two Stuart eye doctors to slop seeing each ether - and stop writing keys to each other as tong as they are embroiled in a cantankinouS Mel fight freed with accusetions of stalking and defamation. 'Neither one of you is to have any contact with the other,' Circuit Judge Ben Bryan told doctors Robin Fier and Ronald Frankel. He warned that nolating his ceder could not only cost them money but court land them in jail. Frenkel, 43, owner of East Florida Eye Intitur. filed suit in May 1997 accusing her of harassing hen by Ring fraudulent COTIPItiriS about bin and sending him hundreds of tellers, which a psychologist characterized Monday a: 'almost bludgeoning and dripsing with sarcasm and nernecairing' Fier countersued last year claiming he was the victim of libel and slander by Frankel and his wee. Paula Costa No trial date has been set. This case is not about competition.' Frenkets attorney. Robert Crthen said. This is about a doctor who has a path:icy:cat disorder who is vying to keep another doctor from fl eecing? Caton asked Bryan lo pioNblt Fier. 47, owner of her Eye Caro a Surgery Canter, from sending any more letters to In client. They come by tax. They corn* by certified mak. They come by regular mail end they come in my hospital mailbox.' Frankel testded. '(The letters) were acrimonious and humiliating. I felt they was kneeing. demeaning and contentious and lot they did not serve any legitenste medal purpose.' Bryan retro:led elblarneys for both doctors to feasted doctor witting to MM as a modeler to scnen letters that involve the Onion! Pants Frontal said Fier fled dozens cicornplaints spins* Nat with notional and state ophthalmology and medical societies. but none was substantiated. Two psychological exports te ed they Wave Fier has a personality disorder and exhibits behavior that it an abusive and Annear/ye. IX. Richard Greer, a forensic psychiabiSt and medical director of the Department of Psychiatry at Stand: Hospital in Gainesville. said hers letters to his forma- wee. including a sympathy card when she rermanied, revealed an 'unhealthy Perchological stale.' He said Fiors leers -106 sent to Frankel since September - wore not designed to discuss patient treatment, but were 'a harassment designed to gel en emotional rise out of the recipient.' Dr. George Realm tinned Fres tatters were 'overflowing with suspiciousness, perianths, and grandiosity.' When ouestioned by Res attorney. Michael Burg, both experts admitted they had not talked to Fier before reaching a conclusion. They reached theirendings alter reading fetters Fer wrote to Frenkel and inner letters he wrote to his ex-wife after their divorce that landed tarn in jail on a contempt charge in 1996. Critton said he suggested a pan to use a mediator to intercept letters from her and Frenkel several months ago, but coutien find anyone. Illustration: PHOTO (2 C) 1. Drs. Ronald React (let)... 2. ..and Robert Fier hove been at odds ante May 1997. On Monday, Judge Ben Bryan told their attorney: to find a third doctor to serve as a mediator to screen letters loot involve their privet. 0:90 r '999 PAN, Besot Newtoopers. Inc EFTA00723568 •. Isw.com Home .. Newswire Law)oin CLE Center .. LawCatalog .. Our Sites .. Advertise M ALIN We0 site THE f, AW DAILY Sc: tl • HOME • THE AM Um DAILY . LITIGATION DAILY • RANIONGS . VIDEOS • MAGAZ1NE • ADVERTISE • SUBSCRIBE . FREE ACCESS . CONTACT US The Work THE AM LAW DAILY • The elfil6 Demote 8.1008 7.50 PM e ThOWOlk ♦ The Stare Billionaire Slaps Scott Rothstein with Sult ♦ TheOlven PoSic.1 by Bow Bailer The Trent e Mt tanitenent The *Mal any drallopelMnq MIM tanIrre Soper:V.4nd fat TM watt lottpnernlwaVAPpepaaccoOmlwaftrInglIZAtebseinioiloril (I pi un3atOP lien 4) A%) EFTA00723569 falGnan Sum keel Rotuma are SA *riotous &cowry arid depositions The addilin-ol mown Whom SIMKO to $200.000, Ream says. adding thai the whose Eraser has :-Avaesiseer Je2SP:l. Setkdk? • . • oily compricaud ohms to mocha cumin cases ponder.; agesist the AereftiStOftri Adverthemem Insteadof a defortdallusiing a legitimate discussion lath • SIMON to znyi retch e a cast NOthstetns) WI Mae OteillataNNII m dettas from WSx imenettmaiNitti these caner cams he Maitre to hem: be says. citon adds IPA Rechetem's 'Waive limeten tacaoi Included wimp to depose -Stannous Intaidults. OW wool embarrass Epstein- Those individuals include 84 Clinton. David Ropserfield. and Dm& numInmit doss (Mash of Enter ittio traveled elm ine ?coney manager cants/Rival. plena (Rothstein sought access to etsott Mans and other nnonnabon mat he MAO she to potential meson LAW.0011NETWORK to boom he darn to a nne-frouno settleanot.) Cotton declined to comment on the damages Epssede is Seeking from I. • RoIsteesn over the alleged nellement totems. though ha hinled that 610 nrnoont will be at leant 5100,000 add mete the' that R &mopes ate .:LCODetOey" towel Cotton has)t to hear ham tawtetS for Rothstms m es cove intieiit7 Wit and seal Se MIMS yet added whether Claim nil De brought (1 " . 1-0tOtti egutrot other members of Rotheten's demd tern. Radish:in . t'nintnienes Simonetta/4m. t/m tong 1Nby stops on the: says Grieco. no stranger to Nolo X%hafrat triatai profile sex sits. Lar itirn Payer: octiFtiponets et RRA. vas ROthasses Orrin& Imre. Marc MAK a tonnes partner t . t net Dictottno • rim Irveredimelat available tel comment Kelm a comment Comments (0) Save& Shen:: Facctook I Delicious I DigsIII Emma I Reprints 11. Permissions Comments Roam ot(ani* oOniniOnts to The Am Lent Deily Post a comment you lea TypeKey or Typepad OCCOW4. please EILLIII Nome: ectot/hatewMontypettetIcenantantenotettenThoestaimatheN Oel 4) DynOnces I eneo MD EFTA00723570 Mess Sea She WINS we See The lite twdsrdale Wryer Scott Rotted, seem eØ too oullanaoh to to Popular Pages Today SURVEYS Mai) RANKINGS We. Axes fie latest. 1. Associate Pay Cuts Here to Stay. Say Firms, • At Lam 103 Analyst. Cn MIT:EIFT ahlheil Whew:Eon me Daily Bustess Review reported • MA LAW 200 1. The Am Law Daily that We federal government will have first dihe an Rollteleina seized • AMIAN' TECH S. Even Well Tones Down the Holiday Party properly d hes ~et wens Mat the fraud ellegtioni against • M.IST 4. The Bankruptcy Files: Season's Greetings front • Gleam. fee %Onset hem bli the St Æ When man. Chapter II • COMFORT/in S. The Am Law Daily Now, another notonous Ficnelton he. entered 949 PIS" SCORECARD O. The Ugly Side of Sports: An Unsavory took at ♦ VEklaXERS OF Sports and the Law Boroere money «wryer and convicted sex diem* *1Wy Epstein 119E YEAR 7. The American Lawyer - The !Wm/ net Med sue against Rothman. clement, Matte Ontrernera 'wryer *MIDLEVEL ASSOCIATES B. Dealmaker of the Week: Peter Golden of Fried SURVEY cod« a %Moue $.200 Wiwi saretN haretement ~mint that Frank Egsten was Sling t0 pay as a vise to Ire innemors into rid Pena 9. L.A. Lawyer Pleads Guilty to Tax Evasion in • SUMMER ASSOCIATES SURVEY where Epswin.reprememed by Robert Calton. Jr., q West Paw Kickback Scheme • PROBONO Eewhe Gomm. Cridon, Lottlord Coleman. Beg Ns PP sue in 10. S&L Gates Goes to Bat for (Stripper) 'Pole SCORECARD Tax" Palm Beech County Cka* Counts,. Monday. • LITIGATION DWARTMENT OF Ac0pdrg to the 36mage manplant. Epstein 8C0.0.01 Reghlein or THE YEAR 'impact., innermost of rucketoomg that invobeci a saggang penes LATERALS REPORT d aunty swears ~sections or peace. acconoole Snuta, ant . • /Wise Aetterte egregrais dvs lillgebin °hoses' met Smatter' EpsteEt and oMers The • Lew site.liatorn correlanl alto accuses Rotten of forging (Wert owl cobs sad MAGAZNE opinom [1: i,E. .1 ,15,K afI Ifatnidek vslh The Am Law Day, Craton hashed Ott N RoMenem • MCN.4. for frauarkrOr darreng that his Mont had agreed WOW $200 Rehm to NNW civl wino harassment cleargos Ned against Easier, by LAW FIRM INC sewrzl women Mertes scardairms alleganons ogartP ten first atma SIGN-UP for FREE E-MAIL NEWSLETTERS Litigation Z004 to light In 2005. on June 2000 EpstelnA it -sur legal warn nesoMted a plea to two prostitution charges thel Waimea Palm Am Law Daily I Litigation Daily FOCUS EUROPE Bead's Adze chid. %no had awry written a lotter ergicumg state hom Amettcardaser.conl STUDENT EDITION Prosecutors: Epstein was released thk July ter sewing arose a VIDEOS WE In 00I Thrse of the wawa haresaniont salt new Red by Meyers ~bog lor limn the LaW.COT Newswire Hall of Fame Rothstein. Orden says those same lievowS falsely Permed to Federal Judges Pull Bade Awing Retinal Proposals INCISIVE MEDIA MP/ewe marry mote ~Tel WV', cOlatial chinas against Epstein. EVENTS SEC lo Congress: Born Prate Gong Deeper SUBSCRIBE The otkabonal women now wieldy existed. talon soya, adding Pet ADVERTISE they ware mangy introduced to orece Arrestor/ to fund %gam Taketevm d Hate Vi6e0 Foam Youlleae See Leads to ABOUT US boring nis cane Demers Sa ~Pet% Archives Erialt for Ellesoavent FEATURED SPONSORS As a real. Craton says Epstein had lo spend more ~eyes hat defense In apse pirrind ems. and his lawyers wowed up engaging:, Gadget 60s for the 2004 Inriddf Sawn hittodded.wddh diddhatterarriar~dadiimeztotituthdai 0 ci 40," EFTA00723571