Case 9:08-cv-80804-KAM
Case 9:08-cv-80804-KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a JANE DOE #1, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. EPSTEIN'S RESPONSE TO MOTION TO PRESERVE EVIDENCE [DE 121 Defendant Jeffrey Epstein hereby responds to the plaintiff Jane Doe's motion to preserve evidence, as follows: I. The Certificate of Compliance annexed to the plaintiffs motion states that plaintiff's "counsel conferred with counsel for [Mr. Epstein] . . . and [Epstein's] counsel advised that [Epstein] opposelS] this motion." DE 12 at 2 (emphasis added). That certification is inaccurate. 2. On August 21, 2008, counsel for the plaintiff called Kathryn Meyers, Esq. of the Lewis Tein law firm to elicit Epstein's position on this motion. Ms. Meyers responded that she would confer with Mr. Tein and call them back. Less than thirty minutes later, however, plain
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Case 9:08-cv-80804-KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a JANE DOE #1, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. EPSTEIN'S RESPONSE TO MOTION TO PRESERVE EVIDENCE [DE 121 Defendant Jeffrey Epstein hereby responds to the plaintiff Jane Doe's motion to preserve evidence, as follows: I. The Certificate of Compliance annexed to the plaintiffs motion states that plaintiff's "counsel conferred with counsel for [Mr. Epstein] . . . and [Epstein's] counsel advised that [Epstein] opposelS] this motion." DE 12 at 2 (emphasis added). That certification is inaccurate. 2. On August 21, 2008, counsel for the plaintiff called Kathryn Meyers, Esq. of the Lewis Tein law firm to elicit Epstein's position on this motion. Ms. Meyers responded that she would confer with Mr. Tein and call them back. Less than thirty minutes later, however, plain
Persons Referenced (4)
“...KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 4 of 4 Service List Theodore J. Leopold, Esq. Spencer Kuvin, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Pal...”
Mr. TeinJane Doe #1Jeffrey Epstein“...O.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a JANE DOE #1, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. EPSTEIN'S RESPONSE TO MOTION TO PRESERVE EVIDENCE [DE 121 Defendant Jeffrey Epstein...”
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9:08-CV-80804-KAM[email protected][email protected][email protected][email protected]Fax: 305 442 6744Fax: 561 697 2383305 442 1101305 442 6744561 515 3148561 659 8300561 682-3206561 697 2383561 828 0983561 835 8691Related Documents (6)
Case 9:08-cv-80804-KAM
Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Flietit0A ()MO D.C. ELECT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN, [REDACTED - Survivor], and SARAH KELLEN, Defendants. NOTICE OF REMOVAL July 18, 2008 STEVEN M. LARIMORF CLERK D.S. DIST. CT. S.O. OF FLA. • MIAMI In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants, Jeffrey Epstein, hereby remove this action' from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this plaintiff filed virtually the identical lawsuit in this Court. See Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (Fla. 15th Cir. Ct. filed Mar. 6, 2008). Lewis "Fein 1059 044.444vEleuf Skim 340, E0coRuT Go
EPSTEIN BOX INVENTORY
EPSTEIN BOX INVENTORY Box 1: Redwell with different files for each Jane Doe v. Epstein case Cd's with Documents on 2" Supplemental Privilege Log (2) and Bates#s 002111-002266 Redwell with printout of Documents in the 2" Supplemental Privilege Log 6001 Orders 6001 Immunity Request folder Jane Doe v. U.S. 6/23/15 production (redwell) with documents Box 2: Data Demonstratives Kirkland & Ellis LLP— 6 bound copies and 1 color copy Plea Negotiations (redwell) — folders: Non Prosecution Agreement — Final; Attorney Notes re Revised Indictment; Research re Boehm case; Research re possible misdemeanors; Notes re Plea Negotiations; Plea Agreement drafts; Draft Non Prosecution Agreements; Information Packet drafts Corr w. Nathan Dershowitz (file folder) Golderberger Corr (green file folder) Lefcourt Corr. Re: Epstein Corp. Records (green file folder) Non Pros Agrmt & Addendum (file folder) Mtgw/ Ken Starr (file folder) MTarget Letter (file folder) Notes re Post Agreement Commu
EFTA02729648
House Oversight FOIA Index with Page References Only
House Oversight FOIA Index with Page References Only The document only lists FOIA request identifiers and page numbers without any substantive content, names, dates, or allegations. It provides no actionable leads, novel information, or connections to powerful actors. Key insights: Contains FOIA request number 1203982-1.; Lists numerous page references (e.g., pages 30‑167) but no details.; Indicates a deleted page (156).
Case 9:08-cv-80804-KAM
Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 1 of 100 nsor & Associates RepornnE sad Transcripoon. Inc 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 75 Q. Because Mr. Epstein never came to your dad's house, correct? A. Correct. Q. And no one who worked for Mr. Epstein ever did something to your dad's tires, did they? MR. LEOPOLD: Objection. Lack of foundation, predicate. Don't guess. BY MR. TEIN: Q. It's not true that Mr. Epstein almost killed your father, is it? MR. LEOPOLD: Objection. Asked and answered, lack of foundation, predicate. BY MR. TEIN: Q. You can answer. A. No. Q. Now you told the police that you didn't know who was in the car with you and IIIIIII on the day you went to Epstein's house, didn't you? A. Yes. Q. And that was a lie, wasn't it? A. It's the truth. Q. You told the police that there was someone in the car next to you and you specifically said y
CM/ECF - Live natabase - flsd
CM/ECF - Live natabase - flsd Page 1 of 6 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80804-KAM Doe v. Epstein et al Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson ' Case in other court: 15th Judicial Circuit, 50 2008 CA 006596 Cause: 28:1331 Federal Question CLOSED, L1RJ Date Filed: 07/18/2008 • Date Terminated: 10/03/2008 Jury Demand: Plaintiff Nature of Suit: 890 Other Statutory Actions Jurisdiction: Federal Question Plaintiff Jane Doe represented by Spencer Todd Kuvin Ricci Leopold 2925 PGA Boulevard Suite 200 Palm Beach Gardens , FL 33410 Defendant Jeffrey Epstein Fax: 515-2610 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Theodore Jon Leopold Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens , FL 33410 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED represented by Guy Alan Lewis Lewis Tein 3059 Grand Avenue Suite 340 Coconut Gr
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