Jane Doe

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Page 1 043-02.pdf - 1 an attorney at the law firm Panish, Shea & Boyle LLP and am admitted before this Court. I represent Plaintiff Jane Doe in this matter. 2. I respectful...
Page 13 043-02.pdf - 13 MPLAINT.pdf Ms. Maxwell, Please be advised that this office represents a victim of Jeffrey Epstein, Jane Doe, who filed a lawsuit against you on Janua...
Page 15 043-02.pdf - 15 -cv-00484 (JGK) (DCF) Dear Ms. Menninger: Please be advised that we represent a woman identified as plaintiff Jane Doe in the above-referenced litigat...
Page 19 043-02.pdf - 19 WELL, an individual, Defendants. Case No. _____________ COMPLAINT FOR DAMAGES DEMAND FOR JURY TRIAL Plaintiff Jane Doe ("Doe" or "Plaintiff") alleges ...
Page 20 043-02.pdf - 20 heir criminal enterprise and widen their network of additional sexual abuse victims. THE PARTIES 4. Plaintiff Jane Doe is a citizen of the State of Ca...
Page 27 043-02.pdf - 27 Penal Law (“Article 130”). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55. PRAYER FOR RELIEF WHEREFORE, Plaintiff Jane Doe prays for this Court to: 59. Is...
Page 30 043-02.pdf - 30 ea & Boyle LLP 11111 Santa Monica Blvd., Suite 700 Los Angeles, CA 90025 Re: 20-CV-00484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et al., Dear Mr. Gla...
Page 15 059.pdf - 15 girl could describe Mr. Epstein's penis? MR. PIKE: Form. THE WITNESS: No. BY MR. KUVIN: Q. Did Ms. Jane Doe No. 103 describe whether or not she had an...
Page 16 059.pdf - 16 do you want to me to use her name or use the redacted portions of it? Q. Yes. We're discussing Ms. Jane Doe No. 103 at this point. A. "Jane Doe No. 10...
Page 25 059.pdf - 25 IKE: Form. BY MR. KUVIN: Q. Let me ask it this way: Was this a recounting o_f the incident with Ms. Jane Doe No. 103? BY A. No. Q. This is a different...
Page 40 059.pdf - 40 2 13 14 16 A. I think that's when the discussions were back and forth about grand- jury. Q. And Ms~ Jane Doe ro3 was served with a grand jury subpoena...
Page 52 059.pdf - 52 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. A. Q. Page 627 Yes, there was. How about Jane Doe 7? Yes. How about a girl that we haven't d...
Page 59 059.pdf - 59 py of the NP A was filed under seal with the state court. On July 7, 2008, a victim, identified as "Jane Doe," filed in federal court in the Southern ...
Page 62 059.pdf - 62 " as well as honoring its promise to meet with the victims. On September 30, 2019, CVRA petitioner "Jane Doe l" filed in her true name a petition for ...
Page 114 059.pdf - 114 the addendum to Lourie, Menchel, Sloman, and her immediate supervisor, Villafana reported, "another Jane Doe has been identified and interviewed," and...
Page 228 059.pdf - 228 im of, criminal activity. Later, the victim obtained new counsel and joined the CVRA litigation as "Jane Doe #2." 219 In his March 20, 2011 letter, ad...
Page 282 059.pdf - 282 e federal investigation with anyone from the government. 282 In the declaration, Villafana stated, "Jane Doe 2 specifically told me that she did not w...
Page 283 059.pdf - 283 ons violate ... all of the 283 The case agent also noted that the victim who became CVRA petitioner Jane Doe #2 had expressed in her April 2007 video-...
Page 290 059.pdf - 290 on, the case agent spoke to two other victims and relayed their reactions to Villafana in an email: Jane Doe# 14 asked me why [Epstein] was receiving ...
Page 296 059.pdf - 296 ana contacted the attorney who at the time represented the victim who later became CVRA petitioner "Jane Doe #2" to inform him that she "was preparing...
Page 297 059.pdf - 297 ice was prepare[ d] to include in" a federal charging document. Accordingly, the victim who became "Jane Doe #2" was not included on the victim list u...
Page 303 059.pdf - 303 forward on the Federal prosecution of Epstein for his crimes against [her]."329 329 CVRA petitioner Jane Doe #2 also received a January 10, 2008 FBI l...
Page 310 059.pdf - 310 47 Before Epstein's state court plea hearing, Edwards also began representing the victim who became Jane Doe #2. Although OPR focuses on Villafaiia's ...
Page 316 059.pdf - 316 state plea "had some connection to blocking the prosecution of my case." Similarly, CVRA petitioner Jane Doe #2 stated that "no one notified me that [...
Page 317 059.pdf - 317 t for the Southern District of Florida on behalf of Courtney Wild, who was then identified only as "Jane Doe." She was soon joined by a second petitio...
Page 319 059.pdf - 319 evidence to include new victims it had identified since creation of the July 2008 list and whether Jane Doe #2, who had previously given a statement i...
Page 325 059.pdf - 325 New York prosecution in which Epstein had been indicted, "[p ]etitioner and other Epstein 387 Doe, Jane Doe 1 and Jane Doe 2's Submission on Proposed ...
Page 569 059.pdf - 569 l< you very much:::::) 1MR-.-EDWARDST) (I l5elieve tnat tne next~rient-is going) frecord it will be Jane Doe 2~ (JANE-DOE-NO-. -2;) (Good morning ,_yo...
Page 573 059.pdf - 573 thank you for hearing us today__J (THE-COURT;) \You' re very welcome.) 1MR-.-EDWARDS;) \YourHonor, Jane Doe No. 5 would like fo) @Re ak:::::J ~ANE DOE...
Page 596 059.pdf - 596 behalfof-NewYork-------a:-ftorney, Lisal !Bloom.) (I work for her firm, The Bloom Firm::J (vicfims, Jane Doe 6, for the record, Jane Doe 7 and Jane Do...
Page 608 059.pdf - 608 ;) (ThanK y__c5iiJ lYoiirHonor, may it please fne court:::::) (Iwoula-rik~fo) (read a statement for Jane Doe,_!D.y client, wno is present-in) (Weonlyn...
Page 676 059.pdf - 676 ent, Epstein is to pay for Josefsberg to represent the women. Some of the women, most identified as Jane Doe in lawsuits, had already hired attorneys ...
Page 677 059.pdf - 677 he nature of the allegations and their youthful ages, L.M. was paid $1 million, E.W. $2 million and Jane Doe $2.5 million, Edwards said of the settlem...
Page 683 059.pdf - 683 simply refused to testify against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the non-prosecuti...
Page 91 074.pdf - 91 ent, Epstein is to pay for Josefsberg to represent the women. Some of the women, most identified as Jane Doe in lawsuits, had already hired attorneys ...
Page 92 074.pdf - 92 he nature of the allegations and their youthful ages, L.M. was paid $1 million, E.W. $2 million and Jane Doe $2.5 million, Edwards said of the settlem...
Page 98 074.pdf - 98 simply refused to testify against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the non-prosecuti...
Page 192 074.pdf - 192 ent, Epstein is to pay for Josefsberg to represent the women. Some of the women, most identified as Jane Doe in lawsuits, had already hired attorneys ...
Page 193 074.pdf - 193 he nature of the allegations and their youthful ages1 L.M. was paid $1 million1 E.W. $2 million and Jane Doe $2.5 million, Edwards said of the settlem...
Page 199 074.pdf - 199 simply refused to testify against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the non-prosecuti...
Page 2 1078-5.pdf - 2 abused by the now-dead pedophile - who called himself her "Godfather" - when she was 13 years old. Jane Doe met Epstein and his friend, Ghislaine Maxw...
Page 37 1078-5.pdf - 37 places Maxwell in a role that was central to their abuse. One anonymous victim, identified only as Jane Doe, alleged that Epstein and Maxwell "attempt...
Page 73 1078-5.pdf - 73 with Maxwell was Borgerson. Moe also read out a victim impact statement from a woman identified as Jane Doe, who also made the case that Maxwell was a...
Page 94 1078-5.pdf - 94 d from a letter written by another of Maxwell’s alleged victims, who asked to be identified only as Jane Doe. It’s possible that the woman may testify...
Page 3 1251.pdf - 3 ds' Privilege Log Undersigned counsel (as well as Paul Cassell, Esq., as counsel for L.M., E.W. and Jane Doe) has since notified Epstein's counsel, Sc...
Page 18 1251.pdf - 18 tein, case no. 50-2008-CA-028058; c. #48 - Court docket and all court filings reference therein for Jane Doe v. Jeffrey Epstein, case no. 08-cv-80893;...
Page 25 1251.pdf - 25 t W/P Priv. Rodriguez Deposition 10077-10079 08/06/2009 Bradley Edwards Mercedes Estrada RE:Epstein vs. Jane Doe No.101 Joint W/P Priv. & Epstein vs. ...
Page 26 1251.pdf - 26 Horowitz Jacquie Johnson RE: Epstein-Notice of production Joint W /P Priv. from non parties/depo of Jane Doe 10372-10373 09/17/2009 Bradley Edwards Ka...
Page 27 1251.pdf - 27 Copperfeild and Clinton's whereabouts 11340-11341 08/05/2009 Mercedes Bradley Edwards RE:Epstein vs.Jane Doe No.101 & Joint W /P Priv. Estrada 102 113...
Page 35 1251.pdf - 35 ll RE:Jane Doe II v. Epstein Joint W/P Priv. 06876-06879 05/12/2009 Bradley Edwards Stuart Mermelstein RE:Jane Doe II v. Epstein Joint W/P Priv. 06891...
Page 68 1251.pdf - 68 le evidence;protected by privacy rights 01080-01081 06/22/2009 Robert C. Busche! Bradley J. Edwards Jane Doe brother Attorney/Client privilege and/or ...
Page 69 1251.pdf - 69 h Attorney/Client privilege and/or work product 02932 07/17/2009 Christina Fitch Bradley J. Edwards Jane Doe v. Roe Attorney/Client privilege and/or w...
Page 70 1251.pdf - 70 ards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 01118-01120 09/22/2009 Bradley J. MG Jane Doe v. Roe Attorney/Client privilege and/or w...
Page 87 1251.pdf - 87 s Mike Fisten Review of litigation materials 05282-05283 04/09/2009 Beth Williamson Bradley Edwards Jane Doe v. Us 05288-05291 07/22/2009 Bradley Edwa...
Page 92 1251.pdf - 92 dmissible evidence; protected by privacy rights 04425-04428 09/18/2009 Paul Cassell Bradley Edwards Jane Doe Depo Set for the 3ot11 W/P; Attorney Clie...
Page 110 1251.pdf - 110 idence; protected by privacy rights 01743 10/29/2009 Beth Williamson Bradley Edwards New folder for Jane Doe Created W/P; Attorney Client Privilege; I...
Page 125 1251.pdf - 125 ell Bradley J. Activity in case 9:08-cv-80994- Work product; attorney/client privilege; Edwards KAM Jane Doe No. 6 v. Epstein Irrelevant and not reaso...
Page 153 1251.pdf - 153 ssible evidence; protected by privacy rights 06826-06836 04/08/2009 Bradley Edwards Beth Williamson Jane Doe change of address Work product; attorney/...
Page 15 1319.pdf - 15 communications between Edwards (or any other co-counsel) and his three tort clients (L.M., E.W. or Jane Doe). Rather, the majority of the documents ar...
Page 22 1319.pdf - 22 lt Lake City, UT 84112-0730 cassellp@law. utah. edu Limited Intervenor Co-Counsel for L.M, E.W. and Jane Doe Jay Howell Jay Howell & Associates 644 Ce...
Page 23 1319.pdf - 23 ail from Farmer Jaffe 2/16/11 Transcript Excerpt of Meeting with Special Master N/D Docket Excerpt -Jane Doe v. United States, S.D. Fla. Case No. 9:08...
Page 55 1319.pdf - 55 07/07/2008 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Defendant Jane Doe represented by Bradley James Edw...
Page 56 1319.pdf - 56 t Correction and Instruction to Filer re 30 Response/Reply (Other), Response/Reply (Other) filed by Jane Doe. Error - Wrong Event Selected; Correction...
Page 66 1319.pdf - 66 t W/P Priv. Rodriguez Deposition 10077-10079 08/06/2009 Bradley Edwards Mercedes Estrada RE:Epstein vs. Jane Doe No.101 Joint W/P Priv. & Epstein vs. ...
Page 67 1319.pdf - 67 Horowitz Jacquie Johnson RE: Epstein-Notice of production Joint W/P Priv. from non parties/depo of Jane Doe 10372-10373 09/17/2009 Bradley Edwards Kat...
Page 68 1319.pdf - 68 Copperfeild and Clinton's whereabouts 11340-11341 08/05/2009 Mercedes Bradley Edwards RE:Epstein vsJane Doe No.101 & Joint W/P Priv. Estrada 102 11348...
Page 76 1319.pdf - 76 ll RE:Jane Doe II v. Epstein Joint W/P Priv. 06876-06879 05/12/2009 Bradley Edwards Stuart Mermelstein RE:Jane Doe II v. Epstein Joint W/P Priv. 06891...
Page 109 1319.pdf - 109 t privilege and/or work product Edwards 02425-02426 06/17/2009 Susan K. Stirling Bradley J. Edwards Jane Doe v. Dukenik Attorney/Client privilege and/...
Page 110 1319.pdf - 110 h Attorney/Client privilege and/or work product 02932 07/17/2009 Christina Fitch Bradley J. Edwards Jane Doe v. Roe Attorney/Client privilege and/or w...
Page 111 1319.pdf - 111 rds. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 01118-01120 09/22/2009 Bradley J. MG Jane Doe v. Roe Attorney/Client privilege and/or w...
Page 128 1319.pdf - 128 ssible evidence; protected by privacy rights 05282-05283 04/09/2009 Beth Williamson Bradley Edwards Jane Doe v. Us W/P; Attorney Client Privilege; Irr...
Page 133 1319.pdf - 133 dmissible evidence; protected by privacy rights 04425-04428 09/18/2009 Paul Cassell Bradley Edwards Jane Doe Depo Set for the 301" W/P; Attorney Clien...
Page 151 1319.pdf - 151 idence; protected by privacy rights 01743 10/29/2009 Beth Williamson Bradley Edwards New folder for Jane Doe Created W/P; Attorney Client Privilege; I...
Page 166 1319.pdf - 166 ell Bradley J. Activity in case 9:08-cv-80994- Work product; attorney/client privilege; Edwards KAM Jane Doe No. 6 v. Epstein irrelevant and not reaso...
Page 194 1319.pdf - 194 ssible evidence; protected by privacy rights 06837-06839 04/08/2009 Beth Williamson Bradley Edwards Jane Doe change of address Work product; attorney/...
Page 264 1319.pdf - 264 he Southern District of Florida and elsewhere. Several of these victims, including L.M., E.W., and "Jane Doe," were represented by Farmer Jaffe attorn...
Page 268 1319.pdf - 268 ege Log. 23. On March 7, 2018, L.M. and two other minor girls Epstein had sexually abused, E.W. and Jane Doe, filed an emergency motion to intervene a...
Page 270 1319.pdf - 270 leged communications. Counsel for Epstein, Edwards, and the three victims at issue (L.M., E.W., and Jane Doe) all appeared. Counsel for Edwards began ...
Page 272 1319.pdf - 272 rent implications of same." Hearing Trans. at 60:20-61: 14. 33. Counsel for victims L.M., E.W., and Jane Doe also asked Judge Hafele to order Fowler W...
Page 274 1319.pdf - 274 led shortly by Mr. Edwards and by three victims with privileged materials at issue, L.M., E.W., and Jane Doe. 13
Page 284 1319.pdf - 284 ove for address purposes only) Attorney E-Mail: cassellp@law.utah.edu Attorneys for L.M., E.W., and Jane Doe Judge Robert Camey 2281 Saratoga Ln West ...
Page 288 1319.pdf - 288 TO ASSESS SANCTIONS AND COSTS FOR OTHER APPROPRIATE RELIEF Sexual assault victims L.M., E.W., and "Jane Doe" (hereinafter "the Victims"), proceeding p...
Page 291 1319.pdf - 291 p@law.utah.edu Pro Hae Vice Motion Filed Contemporaneously Attorneys for Intervenors L.M, E.W., and Jane Doe 4
Page 31 1327-29.pdf - 31 ything sexual in nature happen 24 during the session? 25 A. At one point he lifted up her shirt and Jane Doe 2 Jane Doe 2 Jane Doe 2 Case 1:15-cv-0743...
Page 7 1338.pdf - 7 hile the Court will allow Edwards to present evidence concerning his three clients' (E.W., L.M. and Jane Doe) claims and general evidence about the nu...
Page 17 1338.pdf - 17 lt Lake City, UT 84112-0730 cassellp@law. utah. edu Limited Intervenor Co-Counsel for L.M, E.W. and Jane Doe Jay Howell Jay Howell & Associates 644 Ce...
Page 63 1338.pdf - 63 150. All witnesses that Defendants have listed on their Witness List not objected to by Plaintiff, Jane Doe. 151. All rebuttal witnesses. 152. All Peo...
Page 72 1338.pdf - 72 gs that the defense is attempting to exclude is any reference to anything other than L.M., E.W. and Jane Doe cases. (Your Honor sug9ested -- and I tho...
Page 18 1417.pdf - 18 Edwards ( or any other co-counsel) and Edwards' and Mr. Cassell's three tort clients (L.M., E.W. or Jane Doe). Rather, the majority of the documents a...
Page 21 1417.pdf - 21 lt Lake City, UT 84112-0730 cassellp@law. utah. edu Limited Intervenor Co-Counsel for L.M, E. W and Jane Doe Jay Howell Jay Howell & Associates 644 Ce...
Page 22 1417.pdf - 22 hristopher Knight, Seth Lehrman and Brad Edwards 5 02/16/11 Hearing Transcript Excerpt, p. 41 6 NIA Jane Doe v. United States, U.S. District Court, So...
Page 44 1417.pdf - 44 07/07/2008 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Defendant Jane Doe represented by Bradley James Edw...
Page 45 1417.pdf - 45 t Correction and Instruction to Filer re 30 Response/Reply (Other), Response/Reply (Other) filed by Jane Doe. Error - Wrong Event Selected; Correction...
Page 55 1417.pdf - 55 t W/P Priv. Rodriguez Deposition 10077-10079 08/06/2009 Bradley Edwards Mercedes Estrada RE:Epstein vs. Jane Doe No.101 Joint W/P Priv. & Epstein vs. ...
Page 56 1417.pdf - 56 Horowitz Jacquie Johnson RE: Epstein-Notice of production Joint W/P Priv. from non parties/depo of Jane Doe 10372-10373 09/17/2009 Bradley Edwards Kat...
Page 57 1417.pdf - 57 Copperfeild and Clinton's whereabouts 11340-11341 08/05/2009 Mercedes Bradley Edwards RE:Epstein vsJane Doe No.101 & Joint W/P Priv. Estrada 102 11348...
Page 65 1417.pdf - 65 ll RE:Jane Doe II v. Epstein Joint W/P Priv. 06876-06879 05/12/2009 Bradley Edwards Stuart Mermelstein RE:Jane Doe II v. Epstein Joint W/P Priv. 06891...
Page 98 1417.pdf - 98 le evidence;protected by privacy rights 01080-01081 06/22/2009 Robert C. Busche! Bradley J. Edwards Jane Doe brother Attorney/Client privilege and/or ...
Page 99 1417.pdf - 99 h Attorney/Client privilege and/or work product 02932 07/17/2009 Christina Fitch Bradley J. Edwards Jane Doe v. Roe Attorney/Client privilege and/or w...
Page 100 1417.pdf - 100 rds. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 01118-01120 09/22/2009 Bradley J. MG Jane Doe v. Roe Attorney/Client privilege and/or w...
Page 117 1417.pdf - 117 ssible evidence; protected by privacy rights 05282-05283 04/09/2009 Beth Williamson Bradley Edwards Jane Doe v. Us W/P; Attorney Client Privilege; Irr...
Page 122 1417.pdf - 122 dmissible evidence; protected by privacy rights 04425-04428 09/18/2009 Paul Cassell Bradley Edwards Jane Doe Depo Set for the 301" W/P; Attorney Clien...
Page 140 1417.pdf - 140 idence; protected by privacy rights 01743 10/29/2009 Beth Williamson Bradley Edwards New folder for Jane Doe Created W/P; Attorney Client Privilege; I...
Page 155 1417.pdf - 155 ell Bradley J. Activity in case 9:08-cv-80994- Work product; attorney/client privilege; Edwards KAM Jane Doe No. 6 v. Epstein irrelevant and not reaso...
Page 183 1417.pdf - 183 ssible evidence; protected by privacy rights 06837-06839 04/08/2009 Beth Williamson Bradley Edwards Jane Doe change of address Work product; attorney/...
Page 79 146.pdf - 79 ! Epstein is to pay for Josefsberg to represent the women1. i Some of the women, most identified as Jane Doe in lawsuits, had already hired attorneys ...
Page 80 146.pdf - 80 of the nature of the allegations and their youthful ages, L.M. waspaid $1 million,E.W. $2million andJane Doe $2.5 million, Edwards said of the settlem...
Page 86 146.pdf - 86 simply refused to testify against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the non-prosecuti...
Page 81 153.pdf - 81 ent, Epstein is to pay for Josefsberg to represent the women, Some of the women, most identified as Jane Doe in lawsuits, had already hired attorneys ...
Page 82 153.pdf - 82 the nature ofthe allegations and their youthful, ages, L.M. Was paid $1 million, E.W. $2 million andJane Doe $2.5 million, Edwards said ofthe settleme...
Page 88 153.pdf - 88 simply refused to testify against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the non-prpsecuti...
Page 91 166.pdf - 91 ment,, Epstein is to pay forJosefsberg to represent the women. Some of the women, most identified asJane Doe in ' lawsuits, had already hired attorney...
Page 92 166.pdf - 92 he nature of the allegations and their youthful ages, L.M. was paid S1 million, E.W. $2 million and Jane Doe $2.5 million, Edwards said of the settlem...
Page 98 166.pdf - 98 simply refused to testify against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the nOn-prosecuti...
Page 27 171.pdf - 27 us. And I have instructed each of them to inform the court reporter that they will be proceeding as Jane Doe so that the court reporter can take them ...
Page 32 171.pdf - 32 ery much. MR. EDWARDS: I believe my next client who is going to speak is probably going to speak as Jane Doe. JANE DOE NO. 1: Yes, Jane Doe. THE COURT...
Page 34 171.pdf - 34 . THE COURT: Thank you very much. MR. EDWARDS: I believe that the next client is going to also be a Jane Doe; so I think for the purposes of the recor...
Page 36 171.pdf - 36 . EDWARDS: Okay. I think that the next person who is going to speak is also going to be speaking as Jane Doe; so for the purpose of the record, Jane D...
Page 37 171.pdf - 37 his actions. So I thank you for your time. THE COURT: You're very welcome. MR. EDWARDS: Your Honor, Jane Doe No. 4, I believe, is going to speak now. ...
Page 38 171.pdf - 38 e that. So thank you for hearing us today. THE COURT: You're very welcome. MR. EDWARDS: Your Honor, Jane Doe No. 5 would like to speak. JANE DOE NO. 5...
Page 61 171.pdf - 61 loom. I work for her firm, The Bloom Firm. Lisa Bloom represents four of Jeffrey Epstein's victims, Jane Doe 6, for the record, Jane Doe 7 and Jane Do...
Page 62 171.pdf - 62 65 J8RPEPS2 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 Statement of Jane Doe 7. To the Honorable Richard M. Berman. I used to b...
Page 64 171.pdf - 64 tors and public servants working so diligently to find those answers and to right all these wrongs. Jane Doe 7. (Continued on next page) 67 SOUTHERN D...
Page 65 171.pdf - 65 4 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Thanks very much. ; MS. GIBBS: One more. Statement of Jane Doe 8. In the past few weeks, I have had to r...
Page 66 171.pdf - 66 d support in dealing with this case to illustrate that we, Epstein's victims, do matter. Sincerely, Jane Doe 8. On behalf of Lisa Bloom and The Bloom ...
Page 70 171.pdf - 70 to address the court. As they come up, we'll give them the opportunity to say either their name or Jane Doe. SOUTHERN DISTRICT REPORTERS, P.C. (212) 8...
Page 71 171.pdf - 71 4 25 74 J8RsEPS3 By the way, thank you, your Honor, for allowing some of these victims to be called Jane Doe. What number the court affords to them, w...
Page 72 171.pdf - 72 ere I stand becoming more powerful than he will ever be. Thank you. THE COURT: Thank you. JANE DOE: Jane Doe. Um, in 2004, when I was 15 years old, I ...
Page 73 171.pdf - 73 e. MS. ALLRED: Thank you. Your Honor, may it please the court. I would like to read a statement for Jane Doe, my client, who is present in court, but ...
Page 75 171.pdf - 75 he easy way out without any responsibility. Your Honor, the next statement is also a statement of a Jane Doe. May it please the court. I was a 16-year...
Page 81 171.pdf - 81 ictims. Thank you, your Honor. . And then just one last one, and this is much shorter. Statement of Jane Doe, also my client. I was a model in another...
Page 141 171.pdf - 141 ent, Epstein is to pay for Josefsberg to represent the women. Some ofthe women,- most identified as Jane Doe in lawsuits, had already hired attorneys ...
Page 148 171.pdf - 148 simply refused to testily against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the non-prosecuti...
Page 3 2020.11 DOJ Office of Professional Responsibility Report Executive Summary.pdf - 3 opy of the NPA was filed under seal with the state court. On July 7, 2008, a victim, identified as “Jane Doe,” filed in federal court in the Southern ...
Page 6 2020.11 DOJ Office of Professional Responsibility Report Executive Summary.pdf - 6 ” as well as honoring its promise to meet with the victims. On September 30, 2019, CVRA petitioner “Jane Doe 1” filed in her true name a petition for ...
Page 4 2020.11 DOJ Office of Professional Responsibility Report.pdf - 4 opy of the NPA was filed under seal with the state court. On July 7, 2008, a victim, identified as “Jane Doe,” filed in federal court in the Southern ...
Page 7 2020.11 DOJ Office of Professional Responsibility Report.pdf - 7 ” as well as honoring its promise to meet with the victims. On September 30, 2019, CVRA petitioner “Jane Doe 1” filed in her true name a petition for ...
Page 59 2020.11 DOJ Office of Professional Responsibility Report.pdf - 59 the addendum to Lourie, Menchel, Sloman, and her immediate supervisor, Villafaña reported, “another Jane Doe has been identified and interviewed,” and...
Page 173 2020.11 DOJ Office of Professional Responsibility Report.pdf - 173 im of, criminal activity. Later, the victim obtained new counsel and joined the CVRA litigation as “Jane Doe #2.” 219 In his March 20, 2011 letter, ad...
Page 227 2020.11 DOJ Office of Professional Responsibility Report.pdf - 227 e federal investigation with anyone from the government. 282 In the declaration, Villafaña stated, “Jane Doe 2 specifically told me that she did not w...
Page 228 2020.11 DOJ Office of Professional Responsibility Report.pdf - 228 s violate . . . all of the 283 The case agent also noted that the victim who became CVRA petitioner Jane Doe #2 had expressed in her April 2007 video-...
Page 235 2020.11 DOJ Office of Professional Responsibility Report.pdf - 235 on, the case agent spoke to two other victims and relayed their reactions to Villafaña in an email: Jane Doe #14 asked me why [Epstein] was receiving ...
Page 241 2020.11 DOJ Office of Professional Responsibility Report.pdf - 241 aña contacted the attorney who at the time represented the victim who later became CVRA petitioner “Jane Doe #2” to inform him that she “was preparing...
Page 242 2020.11 DOJ Office of Professional Responsibility Report.pdf - 242 fice was prepare[d] to include in” a federal charging document. Accordingly, the victim who became “Jane Doe #2” was not included on the victim list u...
Page 248 2020.11 DOJ Office of Professional Responsibility Report.pdf - 248 forward on the Federal prosecution of Epstein for his crimes against [her].”329 329 CVRA petitioner Jane Doe #2 also received a January 10, 2008 FBI l...
Page 255 2020.11 DOJ Office of Professional Responsibility Report.pdf - 255 47 Before Epstein’s state court plea hearing, Edwards also began representing the victim who became Jane Doe #2. Although OPR focuses on Villafaña’s c...
Page 261 2020.11 DOJ Office of Professional Responsibility Report.pdf - 261 state plea “had some connection to blocking the prosecution of my case.” Similarly, CVRA petitioner Jane Doe #2 stated that “no one notified me that [...
Page 262 2020.11 DOJ Office of Professional Responsibility Report.pdf - 262 t for the Southern District of Florida on behalf of Courtney Wild, who was then identified only as “Jane Doe.” She was soon joined by a second petitio...
Page 264 2020.11 DOJ Office of Professional Responsibility Report.pdf - 264 evidence to include new victims it had identified since creation of the July 2008 list and whether Jane Doe #2, who had previously given a statement i...
Page 270 2020.11 DOJ Office of Professional Responsibility Report.pdf - 270 e New York prosecution in which Epstein had been indicted, “[p]etitioner and other Epstein 387 Doe, Jane Doe 1 and Jane Doe 2’s Submission on Proposed...
Page 78 205.pdf - 78 ent1 Epstein is to pay for Josefsberg to represent the women. Some of the women, most identified as Jane Doe in lawsuits, had already hired attorneys ...
Page 79 205.pdf - 79 he nature of the allegations and their youthful ages, L.M. was paid $1 million, E.W. $2 million and Jane Doe $2.5 million, Edwards said of the settlem...
Page 85 205.pdf - 85 simply refused to testify against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the non-prosecuti...
Page 28 363-11.pdf - 28 interview, Dershowitz, who lives in New York City and winters in Miami Beach, told the Herald that Jane Doe No. 3’s accusations in the federal suit wo...
Page 29 363-11.pdf - 29 baron Robert Maxwell, to operate an international underage sex ring. Edwards and Cassell filed their Jane Doe lawsuit against the U.S. government, alle...
Page 30 363-11.pdf - 30 “Epstein’s purpose in ‘lending’ Jane Doe [along with other young girls] to such powerful people [was] to ingratiate himself with them for bu
Page 27 702.pdf - 27 t W/P Priv. Rodriguez Deposition 10077-10079 08/06/2009 Bradley Edwards Mercedes Estrada RE:Epstein vs. Jane Doe No.101 Joint W/P Priv. & Epstein vs. ...
Page 28 702.pdf - 28 rowitz Jacquie Johnson RE: EpsteiiFNo~ce of production Joint VJ/P Priv. C from non: parties/depo of Jane Doe. ~- ' .. - 10372-10373 09/17/2009 Bradley...
Page 29 702.pdf - 29 Copperfeild and Clinton's whereabouts 11340-11341 08/05/2009 Mercedes Bradley Edwards RE:Epstein vsJane Doe No.101 & Joint W/P Priv. Estrada 102 11348...
Page 67 745.pdf - 67 NOT A CERTIFIED COPY CASE NO: 08-CV-80119-MARRA/JOHNSON CERTIFICATE OF SERVICE SERVICE LIST Jane Doe v. Jeffrey Epstein United States District Court. ...
Page 73 745.pdf - 73 Cl~r-k The name, address, e-mail, and telephone nwnber of the attorney representing (name of party) Jane Doe r-=~==~~!!Sa,,,,_ ____ ~ _ __:__~--------...
Page 74 745.pdf - 74 110 "l'eslify llt a. De~itio<\ ortu Pl"Qdocc Oo,;umcms in aCivH Aciion UNITED STATES DISTRICT COURT Jane Doe Plainriff v. Jeffrey Epstein Defendant fo...
Page 75 745.pdf - 75 ure The name. address. e>-mail. and teli,phOne numbe:r of the attorney repres~nting (name qf parryj Jane Doe ~----------------------, w110 issues or r...
Page 84 745.pdf - 84 its attorneys IRcili-dlng EDWARDS prior to its Implosion - one of which is filed in federa"J c0urt (Jane Doe v. Epstetn, Case No. oa~CIV-80893, U.S.D....
Page 86 745.pdf - 86 ymity with regard to existing or f abrltated clients. they were able to effectively use ·1nitial.s. Jane Doe or other aoonymoul3 designations wl:iich ...
Page 91 745.pdf - 91 lndlviduals had any connection whatsoever with any of the Litigation Team's clients, E.W., L.M. or Jane Doe.
Page 92 745.pdf - 92 e known) and, at times; LM. tn 'hefCMI Action against EPSTEIN: a:) Included clailtiS for damages in Jane Doe's federal :action in excess of $501000,00...
Page 94 745.pdf - 94 .Charge of Property of Epstefn. and to Post .a $15 million, Bond· to· SeCQre Potential Judgment. in Jane Doe y, Epsteln~ c·ase No. 08-CV-8"0893- Marra...
Page 95 745.pdf - 95 ere allegedly selling prescription palnklllers and drugs to pustomers and prostituting .themselves. Jane Doe (federal case) sef:~__$6_0 million from E...
Page 96 745.pdf - 96 d that there was never omf. and or sexual Intercourse; nor did she e)ler touch his genltalla. Yet,. Jane Doe suffered extreme emotional distress wait....
Page 130 745.pdf - 130 t W/P Priv. Rodriguez Deposition 10077-10079 08/06/2009 Bradley Edwards Mercedes Estrada RE:Epstein vs. Jane Doe No.101 Joint W/P Priv. & Epstein vs. ...
Page 131 745.pdf - 131 Horowitz Jacquie Johnson RE: Epstein-Notice of production Joint W/P Priv. from non parties/depo of Jane Doe 10372-10373 09/17/2009 Bradley Edwards Kat...
Page 132 745.pdf - 132 Copperfeild and Clinton's whereabouts 11340-11341 08/05/2009 Mercedes Bradley Edwards RE:Epstein vs.Jane Doe No.101 & Joint W/P Priv. Estrada 102 1134...
Page 140 745.pdf - 140 ell RE:Jane Doell v. Epstein Joint W/P Priv. 06876-06879 05/12/2009 Bradley Edwards Stuart Mermelstein RE:Jane Doe II v. Epstein Joint W/P Priv. 06891...
Page 3 773-04 (1).pdf - 3 ious prosecution claim against Epstein, attorney Edwards is also suing the government on behalf of “Jane Doe 1 and Jane Doe 2” and others under the fe...
Page 4 773-04 (1).pdf - 4 o Trump’s security guard and houseman.” The affidavit goes on to say that one of Epstein’s victims “Jane Doe #102” has alleged that she was initially ...
Page 5 773-04 (1).pdf - 5 tors of Epstein’s that were closely connected to Epstein’s child exploitation and sexual abuse.” · “Jane Doe No. 102 stated generally that she was req...
Page 3 773-04.pdf - 3 ious prosecution claim against Epstein, attorney Edwards is also suing the government on behalf of “Jane Doe 1 and Jane Doe 2” and others under the fe...
Page 4 773-04.pdf - 4 o Trump’s security guard and houseman.” The affidavit goes on to say that one of Epstein’s victims “Jane Doe #102” has alleged that she was initially ...
Page 5 773-04.pdf - 5 tors of Epstein’s that were closely connected to Epstein’s child exploitation and sexual abuse.” · “Jane Doe No. 102 stated generally that she was req...
Page 16 787-01.pdf - 16 court by lawyers acting on behalf of Virginia Roberts. Ms Roberts - who is referred to in court as Jane Doe No 3 - claims that she was forced to have ...
Page 25 787-01.pdf - 25 or VIPs at his luxury homes using cameras hidden in the walls of guest bedrooms. The woman known as Jane Doe 3 – said to be 30­year­old Virginia Rober...
Page 27 787-01.pdf - 27 fender but still a friend of the rich and powerful Epstein served 13 months before he was released. Jane Doe’s claims against the Prince come after sh...
Page 35 787-01.pdf - 35 rafficking would be provided to Epstein’s aĴorneys who included Harvard law professor Alan Dershowiĵ. Jane Doe 3, identified as Virginia Roberts, has cla...
Page 36 787-01.pdf - 36 of sexual abuse by Epstein. Court records indicate the number may be higher with one reference to a Jane Doe 103. Epstein’s 97‑page address book, call...
Page 39 787-01.pdf - 39 bankers in the world. However, two of Epstein’s alleged victims, referred to in court documents as Jane Doe 1 and Jane Doe 2, have brought a lawsuit a...
Page 48 787-01.pdf - 48 and the US Virgin Islands. The court document says: "Epstein also sexually traf×cked the then-minor Jane Doe (a name used in US legal proceedings for ...
Page 54 787-01.pdf - 54 nd the US Virgin Islands. The court document says: “Epstein also sexually trafficked the then­minor Jane Doe (a name used in US legal proceedings for ...
Page 61 787-01.pdf - 61 ith the woman whose claims have dogged him for years. Last week, the Prince was accused of abusing 'Jane Doe 3' ­ an anonymous name used in American c...
Page 62 787-01.pdf - 62 ding to the law in Florida. As the papers lodged in the Palm Beach court spell out: 'Epstein forced Jane Doe 3 to have sexual relations with a member ...
Page 7 795 (1).pdf - 7 red: "I would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that [federal] complaint?" Reasonable ...
Page 17 795 (1).pdf - 17 oral sex with females under the age of 18?" A: [Invocation of the Fifth Amendment]); Deposition of Jane Doe, September 24, 2009 and continued March 11...
Page 18 795 (1).pdf - 18 male E.W. brought him to molest. She brought him between 20 and 30 underage females); Deposition of Jane Doe #4, date (hereinafter "Jane Doe #4 Depo")...
Page 19 795 (1).pdf - 19 number of underage girls molested by Epstein through his scheme was in the hundreds. See Complaint, Jane Doe 102 v. Epstein, (hereinafter Jane Doe 102...
Page 21 795 (1).pdf - 21 .W. Depa., Attaclnnent #4 at 215-216. 10. Another of the minor girls Epstein sexually assaulted was Jane Doe; the abuse began when Jane Doe was 14 yea...
Page 22 795 (1).pdf - 22 as to perform sex acts on Nadia Marcinkova (Epstein's live-in sex slave) in Epstein's presence. See Plaintiff Jane Doe's Notice Regarding Evidence of ...
Page 29 795 (1).pdf - 29 minal acts, including sexual assaults. Three of the many girls Epstein had abused - L.M., E.W., and Jane Doe - all requested that Edwards represent th...
Page 30 795 (1).pdf - 30 8, attorney Edwards agreed to represent E.W.; on July 2, 2008, attorney Edwards agreed to represent Jane Doe; and, on July 7, 2008, attorney Edwards a...
Page 32 795 (1).pdf - 32 S. Attorney's office. See Hearing Transcript, July 11, 2008 (Exhibit "Q"). 39. Edwards learned that Jane Doe felt so strongly that the plea bargain wa...
Page 33 795 (1).pdf - 33 nst them in whatever avenue remained open to them. On August 12, 2008, at the request of his client Jane Doe, Brad Edwards filed a civil suit against ...
Page 34 795 (1).pdf - 34 o recover damages for his sexual assault of L.M. See Complaint, L.M. v. Epstein, (Exhibit "V"). 47. Jane Doe's federal complaint indicated that she so...
Page 35 795 (1).pdf - 35 complaint filed by attorney Robert Josephsberg from the law firm of Podhurst Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit "B"). As recounte...
Page 36 795 (1).pdf - 36 s case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Ja...
Page 42 795 (1).pdf - 42 and the news articles classified Clinton as Epstein's friend. (c) the complaint filed on behalf of Jane Doe No. 102 stated generally that she was requ...
Page 44 795 (1).pdf - 44 ralago Club in West Palm Beach because Epstein sexually assaulted an underage girl at the club; (d) Jane Doe No. 102's complaint alleged that Jane Doe...
Page 45 795 (1).pdf - 45 e at Epstein's house, when Dershowitz himself was an eyewitness to their presence at the house; (f) Jane Doe No. 102 stated generally that Epstein for...
Page 47 795 (1).pdf - 47 Discovery of the pilot and flight logs was proper in the cases brought by Edwards against Epstein. Jane Doe filed a federal RICO claim against Epstein...
Page 48 795 (1).pdf - 48 NOT A CERTIFIED COPY Edwards anticipated that Epstein would argue that Jane Doe's proof of the federal nexus was inadequate. These fears were realized...
Page 49 795 (1).pdf - 49 Bradley J. Edwards was the one causing all of Epstein's problems (i.e., the civil suits brought by Jane Doe and other girls); • L.M. came to him as a ...
Page 50 795 (1).pdf - 50 (see Exhibit C, supra), Edwards learned that Epstein continued to harass his victims. For example, Jane Doe had a trial set for her civil case against...
Page 51 795 (1).pdf - 51 2010, rather than face trial for the civil suits that had been filed against him by L.M., E.W., and Jane Doe, defendant Epstein settled the cases agai...
Page 54 795 (1).pdf - 54 Epstein took the Fifth rather than answer a question about the actual value of the claim ofL.M. and Jane Doe against him. Id. 101. In bis deposition, ...
Page 60 795 (1).pdf - 60 finn in Hollywood,, FL. While a sole practitioner I was retained by three clients, L.M., E.W., and Jane Doe to pursue civil litigation against Jeffrey...
Page 61 795 (1).pdf - 61 lP .A. ("RRA"). I brought my existing clients with me when I joined RRA, including L.M., E.W., and Jane Doe. When I joined the furn, I was not aware t...
Page 62 795 (1).pdf - 62 intention of reruming and certainly wowd not return. to the United States before the conclusion of Jane Doe's trial period (August 6, 2010). Despite t...
Page 63 795 (1).pdf - 63 pstein's house, despite him being an eyewitness that the underage girls well."e actually there; (f) Jane Doe No. 102 stated generally that Epstein for...
Page 65 795 (1).pdf - 65 NOT A CERTIFIED COPY necessary because: (a) Jane Doe filed a federal RICO claim against Epstein that was an active claim through much of the litigatio...
Page 67 795 (1).pdf - 67 gitimate claims against Epstein. Epstein sexually abused three clients of Edwards - L.M., E.W., and Jane Doe - and Edwards properly and successfully E...
Page 68 795 (1).pdf - 68 re told by Rothstein that three minor girls who were sexually assaulted by Epstein: L.M., E.W., and Jane Doe were to be paid up-front money to prevent...
Page 75 795 (1).pdf - 75 e civil cases he had filed against Epstein. Edwards represented three young women - L.M., E.W., and Jane Doe - by filing civil suits against Epstein f...
Page 77 795 (1).pdf - 77 esult of a federal court ordered mediation process, which he himself sought ( over the objection of Jane Doe, Edwards' client in federal court) in an ...
Page 79 795 (1).pdf - 79 out were in fact used for the immediate purpose of furthering the lawsuits filed by L.M., E.W., and Jane Doe. In other words, these actions all were b...
Page 81 795 (1).pdf - 81 ce to the case - even acts of abuse Epstein committed against minor girls other than L.M., E.W., or Jane Doe. Both federal and state evidence rules ma...
Page 84 795 (1).pdf - 84 " 11 "I would like to lmow whether you ever had any physical contact with the person referred to as Jane Doe in that [federal] complaint?" • "Did you ...
Page 86 795 (1).pdf - 86 red: "I would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that [federal] complaint?" Reasonable ...
Page 94 795 (1).pdf - 94 egitimate claims against Epstein. Epstein sexually abused three clients of Edwards -L.M., E.W., and Jane Doe- and Edwards properly and successfully re...
Page 95 795 (1).pdf - 95 re told by Rothstein that three minor girls who were sexually assaulted by Epstein: L.M., E.W., and Jane Doe were to be paid up-front money to prevent...
Page 105 795 (1).pdf - 105 result of a federal court ordered mediation process, which he himself sought (over the objection of Jane Doe, Edwards' client in federal court) in an ...
Page 107 795 (1).pdf - 107 n fact used for the immediate purpose of furthering the lawsuits filed on behalf of L.M., E.W., and Jane Doe. In other words, these actions all were b...
Page 110 795 (1).pdf - 110 ce to the case - even acts of abuse Epstein committed against minor girls other than L.M., E.W., or Jane Doe. Both federal and state evidence rules ma...
Page 112 795 (1).pdf - 112 " • "I would like to know whether you ever had any physical contact with the person ref erred to as Jane Doe 111 that [:federal]coinplaint?" • • "Did ...
Page 115 795 (1).pdf - 115 "I would like to know whether you ever had any physical· • contact with the person re:ferred~td as Jane Doe 'iii ·that [federal]. compfairit?" Reasona...
Page 162 795 (1).pdf - 162 d -- or let me strike that. There are three cases that are in existence at the current time. One is Jane Doe versus Mr. Epstein which is, is a federal...
Page 167 795 (1).pdf - 167 cally the -- well, let me Page 29 strike that. During the time you were at RRA, of the three files, Jane Doe, L.M., and E.W. or in addition to those t...
Page 168 795 (1).pdf - 168 used Qtask during the time you were with RRA? A. Yes. Q. And when you say a project, as an example, Jane Doe versus Jeffrey Epstein, if that had been ...
Page 169 795 (1).pdf - 169 ask program for, for purposes of creating a project? A. Repeat it again. Q. Okay. Could a case like Jane Doe versus Jeffrey Epstein been put in the Qt...
Page 170 795 (1).pdf - 170 d ifl understand it correctly is in terms of the project, is if it was, if it was as an example the Jane Doe case, you could, you or anyone else could...
Page 171 795 (1).pdf - 171 I think the answer is yes. Q. Now, with regard to the three cases that you -- well, with regard to Jane Doe versus Jeffrey Epstein, I think you alread...
Page 172 795 (1).pdf - 172 lse, whether it was another attorney, whether it was an investigator or a staff person ever put the Jane Doe versus Epstein case on Qtask? A. Or wheth...
Page 173 795 (1).pdf - 173 se. Was any information about the, your three clients put into the Qtask, about your three clients, Jane Doe, E.W., and L.M. versus Jeffrey Epstein, o...
Page 174 795 (1).pdf - 174 . Q. And maybe I should get a definition of, with regard to the Epstein files, you had three cases, Jane Doe, E.W., and L.M., correct? MR. SCAROLA: Ex...
Page 179 795 (1).pdf - 179 ed up at that office? A. No. Q. And in terms of the cases; that is, the cases with L.M., with L.M., Jane Doe and E.W. those are cases that you had sig...
Page 180 795 (1).pdf - 180 ere was at least two contracts with regard to E.W.? A. That I remember. Q. And with regard to E.W., Jane Doe, and L.M., you don't recall any new contr...
Page 181 795 (1).pdf - 181 ttlement or verdict been 15 assigned or sold to anyone to your knowledge? 16 A. No. 17 Q. Has E.W., Jane Doe, or L.M. sold, 18 assigned, exchanged for...
Page 182 795 (1).pdf - 182 tein or to the United States Government? A. I don't remember. Q. You ultimately filed a case styled Jane Doe 1 and 2 were petitioners versus the Unite...
Page 184 795 (1).pdf - 184 .W.? A. No. Q. I think you told me at the time that the complaint was filed or at the time that the Jane Doe 1 and 2 sued the United States Government...
Page 185 795 (1).pdf - 185 y that whether again prior to the -- let me start again. Prior to the filing of the lawsuit against Jane Doe 1 and Jane Doe 2 against the United State...
Page 186 795 (1).pdf - 186 east for now. MR. CRITTON: I'm shocked. BY MR. CRITTON: Q. With regard to, with regard to the claim Jane Doe 1 and Jane Doe 2 that is currently pendin...
Page 192 795 (1).pdf - 192 before. Q. Did you discuss the facts and circumstances of the cases with him? A. OfL.M., E.W., and Jane Doe's specific circumstances, no. In fact, I w...
Page 195 795 (1).pdf - 195 of the local television stations. BY lvIR. CRITTON: Q. Which of your clients gave the interview? A. Jane Doe. Q. And did you organize that? A. I assis...
Page 196 795 (1).pdf - 196 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 145 I believe that's 1ight. Q. As a result of Jane Doe speaking with the press, did she receive a...
Page 199 795 (1).pdf - 199 am going to be answering today. Q. With regard to at least you have attended the deposition of both Jane Doe and ofL.M, correct? A Yes. Q. Okay. And h...
Page 204 795 (1).pdf - 204 pecific case such as if you wanted to know how much in costs had been incurred by Mr. Epstein -- on Jane Doe's case while at the RRA firm, could you r...
Page 214 795 (1).pdf - 214 Edwards, you knew or you first Marie 1 7 Villafana through the complaint you filed on behalf 18 of Jane Doe 1 and Jane Doe 2 in July of 2008, 19 corre...
Page 215 795 (1).pdf - 215 ions that you have had with Mr. Marie Villafana or Villafana, have they only been in the context of Jane Doe 1 and 2 versus United States of America, ...
Page 231 795 (1).pdf - 231 to Mr., with regard to the depositions of -- well, let me strike that. Also listed both on your, on Jane Doe's and L.W.'s and E.W.'s updated interroga...
Page 233 795 (1).pdf - 233 s. Q. Who was present? A. Bill Berger. Q. Did a_fly RF-A. lawyer ever have an occasion to meet with Jane Doe at, at a location other than your office;...
Page 236 795 (1).pdf - 236 ott Rothstein had represented to other individuals that he had multiple other cases, multiple other Jane Doe's which he was trying to market to invest...
Page 278 795 (1).pdf - 278 Things such as -- at the same time, this -- Rule 26 disclosures, and Jane 1 -- and .lane Doe 1 and Jane Doe 2, those are your CRVA {SIC} cases, correc...
Page 286 795 (1).pdf - 286 efore you settled them, if you -- A lTh, from memory -- Q Yeah, I'm not- A -- the case was a -- the Jane Doe v. Epstein case was initially set for tri...
Page 288 795 (1).pdf - 288 u --you didn't know it was coming, obviously? A Right. Q You were only involved at that time in the Jane Doe, let me just call them Jane Doe, whatever...
Page 314 795 (1).pdf - 314 t near resolution? 2 A I don't know. 3 Q Is -- can you tell me the style of the case? 4 A Yes, it's Jane Doe I and Jane Doe II versus 5 United States ...
Page 7 795.pdf - 7 red: "I would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that [federal] complaint?" Reasonable ...
Page 17 795.pdf - 17 oral sex with females under the age of 18?" A: [Invocation of the Fifth Amendment]); Deposition of Jane Doe, September 24, 2009 and continued March 11...
Page 18 795.pdf - 18 male E.W. brought him to molest. She brought him between 20 and 30 underage females); Deposition of Jane Doe #4, date (hereinafter "Jane Doe #4 Depo")...
Page 19 795.pdf - 19 number of underage girls molested by Epstein through his scheme was in the hundreds. See Complaint, Jane Doe 102 v. Epstein, (hereinafter Jane Doe 102...
Page 21 795.pdf - 21 .W. Depa., Attaclnnent #4 at 215-216. 10. Another of the minor girls Epstein sexually assaulted was Jane Doe; the abuse began when Jane Doe was 14 yea...
Page 22 795.pdf - 22 as to perform sex acts on Nadia Marcinkova (Epstein's live-in sex slave) in Epstein's presence. See Plaintiff Jane Doe's Notice Regarding Evidence of ...
Page 29 795.pdf - 29 minal acts, including sexual assaults. Three of the many girls Epstein had abused - L.M., E.W., and Jane Doe - all requested that Edwards represent th...
Page 30 795.pdf - 30 8, attorney Edwards agreed to represent E.W.; on July 2, 2008, attorney Edwards agreed to represent Jane Doe; and, on July 7, 2008, attorney Edwards a...
Page 32 795.pdf - 32 S. Attorney's office. See Hearing Transcript, July 11, 2008 (Exhibit "Q"). 39. Edwards learned that Jane Doe felt so strongly that the plea bargain wa...
Page 33 795.pdf - 33 nst them in whatever avenue remained open to them. On August 12, 2008, at the request of his client Jane Doe, Brad Edwards filed a civil suit against ...
Page 34 795.pdf - 34 o recover damages for his sexual assault of L.M. See Complaint, L.M. v. Epstein, (Exhibit "V"). 47. Jane Doe's federal complaint indicated that she so...
Page 35 795.pdf - 35 complaint filed by attorney Robert Josephsberg from the law firm of Podhurst Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit "B"). As recounte...
Page 36 795.pdf - 36 s case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Ja...
Page 42 795.pdf - 42 and the news articles classified Clinton as Epstein's friend. (c) the complaint filed on behalf of Jane Doe No. 102 stated generally that she was requ...
Page 44 795.pdf - 44 ralago Club in West Palm Beach because Epstein sexually assaulted an underage girl at the club; (d) Jane Doe No. 102's complaint alleged that Jane Doe...
Page 45 795.pdf - 45 e at Epstein's house, when Dershowitz himself was an eyewitness to their presence at the house; (f) Jane Doe No. 102 stated generally that Epstein for...
Page 47 795.pdf - 47 Discovery of the pilot and flight logs was proper in the cases brought by Edwards against Epstein. Jane Doe filed a federal RICO claim against Epstein...
Page 48 795.pdf - 48 NOT A CERTIFIED COPY Edwards anticipated that Epstein would argue that Jane Doe's proof of the federal nexus was inadequate. These fears were realized...
Page 49 795.pdf - 49 Bradley J. Edwards was the one causing all of Epstein's problems (i.e., the civil suits brought by Jane Doe and other girls); • L.M. came to him as a ...
Page 50 795.pdf - 50 (see Exhibit C, supra), Edwards learned that Epstein continued to harass his victims. For example, Jane Doe had a trial set for her civil case against...
Page 51 795.pdf - 51 2010, rather than face trial for the civil suits that had been filed against him by L.M., E.W., and Jane Doe, defendant Epstein settled the cases agai...
Page 54 795.pdf - 54 Epstein took the Fifth rather than answer a question about the actual value of the claim ofL.M. and Jane Doe against him. Id. 101. In bis deposition, ...
Page 60 795.pdf - 60 finn in Hollywood,, FL. While a sole practitioner I was retained by three clients, L.M., E.W., and Jane Doe to pursue civil litigation against Jeffrey...
Page 61 795.pdf - 61 lP .A. ("RRA"). I brought my existing clients with me when I joined RRA, including L.M., E.W., and Jane Doe. When I joined the furn, I was not aware t...
Page 62 795.pdf - 62 intention of reruming and certainly wowd not return. to the United States before the conclusion of Jane Doe's trial period (August 6, 2010). Despite t...
Page 63 795.pdf - 63 pstein's house, despite him being an eyewitness that the underage girls well."e actually there; (f) Jane Doe No. 102 stated generally that Epstein for...
Page 65 795.pdf - 65 NOT A CERTIFIED COPY necessary because: (a) Jane Doe filed a federal RICO claim against Epstein that was an active claim through much of the litigatio...
Page 67 795.pdf - 67 gitimate claims against Epstein. Epstein sexually abused three clients of Edwards - L.M., E.W., and Jane Doe - and Edwards properly and successfully E...
Page 68 795.pdf - 68 re told by Rothstein that three minor girls who were sexually assaulted by Epstein: L.M., E.W., and Jane Doe were to be paid up-front money to prevent...
Page 75 795.pdf - 75 e civil cases he had filed against Epstein. Edwards represented three young women - L.M., E.W., and Jane Doe - by filing civil suits against Epstein f...
Page 77 795.pdf - 77 esult of a federal court ordered mediation process, which he himself sought ( over the objection of Jane Doe, Edwards' client in federal court) in an ...
Page 79 795.pdf - 79 out were in fact used for the immediate purpose of furthering the lawsuits filed by L.M., E.W., and Jane Doe. In other words, these actions all were b...
Page 81 795.pdf - 81 ce to the case - even acts of abuse Epstein committed against minor girls other than L.M., E.W., or Jane Doe. Both federal and state evidence rules ma...
Page 84 795.pdf - 84 " 11 "I would like to lmow whether you ever had any physical contact with the person referred to as Jane Doe in that [federal] complaint?" • "Did you ...
Page 86 795.pdf - 86 red: "I would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that [federal] complaint?" Reasonable ...
Page 94 795.pdf - 94 egitimate claims against Epstein. Epstein sexually abused three clients of Edwards -L.M., E.W., and Jane Doe- and Edwards properly and successfully re...
Page 95 795.pdf - 95 re told by Rothstein that three minor girls who were sexually assaulted by Epstein: L.M., E.W., and Jane Doe were to be paid up-front money to prevent...
Page 105 795.pdf - 105 result of a federal court ordered mediation process, which he himself sought (over the objection of Jane Doe, Edwards' client in federal court) in an ...
Page 107 795.pdf - 107 n fact used for the immediate purpose of furthering the lawsuits filed on behalf of L.M., E.W., and Jane Doe. In other words, these actions all were b...
Page 110 795.pdf - 110 ce to the case - even acts of abuse Epstein committed against minor girls other than L.M., E.W., or Jane Doe. Both federal and state evidence rules ma...
Page 112 795.pdf - 112 " • "I would like to know whether you ever had any physical contact with the person ref erred to as Jane Doe 111 that [:federal]coinplaint?" • • "Did ...
Page 115 795.pdf - 115 "I would like to know whether you ever had any physical· • contact with the person re:ferred~td as Jane Doe 'iii ·that [federal]. compfairit?" Reasona...
Page 162 795.pdf - 162 d -- or let me strike that. There are three cases that are in existence at the current time. One is Jane Doe versus Mr. Epstein which is, is a federal...
Page 167 795.pdf - 167 cally the -- well, let me Page 29 strike that. During the time you were at RRA, of the three files, Jane Doe, L.M., and E.W. or in addition to those t...
Page 168 795.pdf - 168 used Qtask during the time you were with RRA? A. Yes. Q. And when you say a project, as an example, Jane Doe versus Jeffrey Epstein, if that had been ...
Page 169 795.pdf - 169 ask program for, for purposes of creating a project? A. Repeat it again. Q. Okay. Could a case like Jane Doe versus Jeffrey Epstein been put in the Qt...
Page 170 795.pdf - 170 d ifl understand it correctly is in terms of the project, is if it was, if it was as an example the Jane Doe case, you could, you or anyone else could...
Page 171 795.pdf - 171 I think the answer is yes. Q. Now, with regard to the three cases that you -- well, with regard to Jane Doe versus Jeffrey Epstein, I think you alread...
Page 172 795.pdf - 172 lse, whether it was another attorney, whether it was an investigator or a staff person ever put the Jane Doe versus Epstein case on Qtask? A. Or wheth...
Page 173 795.pdf - 173 se. Was any information about the, your three clients put into the Qtask, about your three clients, Jane Doe, E.W., and L.M. versus Jeffrey Epstein, o...
Page 174 795.pdf - 174 . Q. And maybe I should get a definition of, with regard to the Epstein files, you had three cases, Jane Doe, E.W., and L.M., correct? MR. SCAROLA: Ex...
Page 179 795.pdf - 179 ed up at that office? A. No. Q. And in terms of the cases; that is, the cases with L.M., with L.M., Jane Doe and E.W. those are cases that you had sig...
Page 180 795.pdf - 180 ere was at least two contracts with regard to E.W.? A. That I remember. Q. And with regard to E.W., Jane Doe, and L.M., you don't recall any new contr...
Page 181 795.pdf - 181 ttlement or verdict been 15 assigned or sold to anyone to your knowledge? 16 A. No. 17 Q. Has E.W., Jane Doe, or L.M. sold, 18 assigned, exchanged for...
Page 182 795.pdf - 182 tein or to the United States Government? A. I don't remember. Q. You ultimately filed a case styled Jane Doe 1 and 2 were petitioners versus the Unite...
Page 184 795.pdf - 184 .W.? A. No. Q. I think you told me at the time that the complaint was filed or at the time that the Jane Doe 1 and 2 sued the United States Government...
Page 185 795.pdf - 185 y that whether again prior to the -- let me start again. Prior to the filing of the lawsuit against Jane Doe 1 and Jane Doe 2 against the United State...
Page 186 795.pdf - 186 east for now. MR. CRITTON: I'm shocked. BY MR. CRITTON: Q. With regard to, with regard to the claim Jane Doe 1 and Jane Doe 2 that is currently pendin...
Page 192 795.pdf - 192 before. Q. Did you discuss the facts and circumstances of the cases with him? A. OfL.M., E.W., and Jane Doe's specific circumstances, no. In fact, I w...
Page 195 795.pdf - 195 of the local television stations. BY lvIR. CRITTON: Q. Which of your clients gave the interview? A. Jane Doe. Q. And did you organize that? A. I assis...
Page 196 795.pdf - 196 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 145 I believe that's 1ight. Q. As a result of Jane Doe speaking with the press, did she receive a...
Page 199 795.pdf - 199 am going to be answering today. Q. With regard to at least you have attended the deposition of both Jane Doe and ofL.M, correct? A Yes. Q. Okay. And h...
Page 204 795.pdf - 204 pecific case such as if you wanted to know how much in costs had been incurred by Mr. Epstein -- on Jane Doe's case while at the RRA firm, could you r...
Page 214 795.pdf - 214 Edwards, you knew or you first Marie 1 7 Villafana through the complaint you filed on behalf 18 of Jane Doe 1 and Jane Doe 2 in July of 2008, 19 corre...
Page 215 795.pdf - 215 ions that you have had with Mr. Marie Villafana or Villafana, have they only been in the context of Jane Doe 1 and 2 versus United States of America, ...
Page 231 795.pdf - 231 to Mr., with regard to the depositions of -- well, let me strike that. Also listed both on your, on Jane Doe's and L.W.'s and E.W.'s updated interroga...
Page 233 795.pdf - 233 s. Q. Who was present? A. Bill Berger. Q. Did a_fly RF-A. lawyer ever have an occasion to meet with Jane Doe at, at a location other than your office;...
Page 236 795.pdf - 236 ott Rothstein had represented to other individuals that he had multiple other cases, multiple other Jane Doe's which he was trying to market to invest...
Page 278 795.pdf - 278 Things such as -- at the same time, this -- Rule 26 disclosures, and Jane 1 -- and .lane Doe 1 and Jane Doe 2, those are your CRVA {SIC} cases, correc...
Page 286 795.pdf - 286 efore you settled them, if you -- A lTh, from memory -- Q Yeah, I'm not- A -- the case was a -- the Jane Doe v. Epstein case was initially set for tri...
Page 288 795.pdf - 288 u --you didn't know it was coming, obviously? A Right. Q You were only involved at that time in the Jane Doe, let me just call them Jane Doe, whatever...
Page 314 795.pdf - 314 t near resolution? 2 A I don't know. 3 Q Is -- can you tell me the style of the case? 4 A Yes, it's Jane Doe I and Jane Doe II versus 5 United States ...
Page 3 EFTA00009512.pdf VOL00007 3 ts and charges 4 related to Jane Does number 1 and 2? 5 A Yes. 6 Q Today we are going to start with Jane Doe 7 number 3. Can you tell the Grand Jury w...
Page 5 EFTA00009512.pdf VOL00007 5 questions about 3 when IIIII was providing massages and as we will 4 talk about when we talk about Jane Doe number 4, which 5 is , she told Mr. Epstei...
Page 6 EFTA00009512.pdf VOL00007 6 6 1 Q Yes. 2 (Thereupon, there was a brief pause.) 3 A I will let you see a picture of Jane Doe 4 number 4, , who we were talking about earlier, and 5...
Page 9 EFTA00009512.pdf VOL00007 9 rformed these lewd acts, correct? 6 A ves, 8200. 7 Q And is listed as a defendant with 8 respect to Jane Doe number 3 as well, and can you 9 explain t...
Page 16 EFTA00009512.pdf VOL00007 16 to Count 13 number 51 which appears on page 33, that is the sex 14 trafficking of a minor involving Jane Doe number 3, and 15 could you briefly summar...
Page 17 EFTA00009512.pdf VOL00007 17 tivity, correct? 8 A Yes, we do. 9 Q Is there anything else that you would like to 10 mention about Jane Doe number 3? 11 A Not at this time, no. 12 Q...
Page 22 EFTA00009512.pdf VOL00007 22 nt to overt act number 4 which appears on 12 page number 5. 13 Did you obtain telephone records for Jane Doe 14 number 4? 15 A Yes. 16 Q And did you c...
Page 25 EFTA00009512.pdf VOL00007 25 says on March 18th, 2005 19 defendant prepared a written message to defendant 20 Epstein regarding Jane Doe number 4, could you tell the 21 Grand Jury...
Page 27 EFTA00009512.pdf VOL00007 27 27 1 2005 Jeffrey Epstein, IIIII , IIIIIII IIII enticed 2 3 Jane Doe number 4 to engage in sexual activity or prostitution. 4 A On or about these date...
Page 30 EFTA00009512.pdf VOL00007 30 ct on January 5 6th -- excuse me, shortly before the flight on January 6 6th, 2005 between and this Jane Doe? 7 A Yes, two days before. 8 Q And if you...
Page 32 EFTA00009512.pdf VOL00007 32 32 1 fact they were adults? 2 A Yes. 3 Q Any questions about Jane Doe number 4 before 4 we turn to Jane Doe number 5? Yes, A GRAND JUROR: I have to sa...
Page 34 EFTA00009512.pdf VOL00007 34 y. Any other 10 factual questions related? 11 A GRAND JUROR: I don't have a question 12 relating to Jane Doe number 4, it was a question 13 asked last...
Page 22 EFTA00009550.pdf VOL00007 22 Yes. 13 Q Let's turn to the specific evidence reporting 14 the overt acts and offenses relating to Jane Doe's 1 15 through 5. I know that every member...
Page 23 EFTA00009550.pdf VOL00007 23 Page 23 Q And Jane Doe Number 1, you have previously testified about her? A Yes, I have, that's . Q Jane Doe Number 2? A That is 6 Q Jane Doe Number 3...
Page 24 EFTA00009550.pdf VOL00007 24 3 Can I ask about that? We were told back in February 4 5 6 7 8 10 11 12 BY MS. 13 Q So turning to Jane Doe Number 1, 1. You 14 testified about her ea...
Page 25 EFTA00009550.pdf VOL00007 25 on page five. That states, °On or about 14 March 12, 2004, defendants Jeffrey Epstein and 15 caused Jane Doe Number 1 to travel to 358 Brillo Way of 1...
Page 26 EFTA00009550.pdf VOL00007 26 a look at Overt Act Number 95, 15 which is on page 17. On or about February 6, 2005, 16 Epstein had Jane Doe Number 1 to make one or more 17 telephone...
Page 27 EFTA00009550.pdf VOL00007 27 house? 5 A Yes. 6 Q Looking at Overt Act Number 96. On or about 7 February 6, 2005, Epstein caused Jane Doe Number 1 to 8 transport Jane Doe Number 2 ...
Page 28 EFTA00009550.pdf VOL00007 28 states that on or about March 30, 2005, caused one or more calls to be made to a telephone used by Jane Doe Number 1. what evidence do you have relate...
Page 30 EFTA00009550.pdf VOL00007 30 nt Number Five, which appears on page 26. That is the charge of enticement of a minor, referring to Jane Doe Number 1, and Mr. Epstein and are charged...
Page 31 EFTA00009550.pdf VOL00007 31 here any questions about 6 either how that evidence was presented or about the 7 charges related to Jane Doe Number 1? Seeing no 8 questions, we'll tu...
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