UNITED DISTRICT COURT SOUTHE-3.4RN DISTRICT OF FLORIDA JANE CAS-3.5E NO 93-CIV-MARRA/JOHNSON Plaintiff Vs JEFFREY EPST-4.5EIN et al Defendant Related Cases PLAINTIFF-5.1 JANE NOTICE THAT ADDITIONAL EVIDENCE OF EPSTEIN?S FRAUDUL-5.5ENT TRANSF-5.5ERS WILL BE FILED SHORTL-4.8Y AND MOTION FOR Plaintiff Jane Doe Case hereby gives to the Court that she will shortly be f-7.6iling additional of fraudul ent asset transfers by Jeffrey Epstein and to move the court to consider these materi als and all of the mate rials found in Docket-7.5 Numbers and in determining whether to grant Jane Doe?s-5 Motion for Injunction Restraining Fraudulent-7.2 Transfer of Assets in case no ADDITIONAL EVIDE-3.5NCE OF EPSTEIN?S FRAUDUL-5.7ENT TRANSF-5.7ERS WILL BE FILED SHORTLY the Court knows on June Jane Doe filed a motion asking for appointment of a rec-5e1.2iver to take control of defendant Jeffrey Epstein?s-5 assets and Case Document Entered on FLSD Docket Page of CASE NO post a million bo-4.3nd to secure any pote-4.3n.7tial judgm-7.7ent in this case DE in case-4.5 no The motion)-3.9 alle-3.9ged th-3.9at Epstein was hiding-4.7 hundr eds millions dollars in assets in an effo rt to defeat any-5 judgment that Jane Doe and many othe-4.5r victims of his child se xual abuse might obtain against hi On Epstein filed his r-7.3e.9sponse Without s-5.2pecifically denying any of Jane Doe?s allegations of fraudulent t-7.6r-2.4ansfers Epstein argued that Jane Doe lack-4.9ed proof of such transfers DE Doe filed a reply-4.5 to Epstein?s re sponse on DE But in addition to the information and ar-7.2guments prov ided there Jane Doe now wants to alert the Court to newly-discovered evidence bol stering her arguments regarding Epstein?s-10.8 fraudulent concealment of his assets Yest erday October couns)-5.3e.9l for Jane Doe took deposition of Larry Visosk-5.4i who has been Jeffrey Ep stein?s personal pilot-7.6 for approximately years flying for ex ample Epstein?s Boeing jet declared that in the last year Epstein has transferred to him four very valuable and a boat-7.8 and registered them in his Vis-5.6osk i?s name A transcript of the deposition will not be available until Oct ober But in view of the extreme relevance of this information to Jane Doe?s ending-motion she wanted to advise the Court of the substance of this testimony immediately and will pr-7.9ovide prec-5.5ise quotations from the deposition as soon as it is available a pr-7.1ecise trans-5.1cript is not yet avai lable counsel represents that during the deposition Visosk-5.3i testified that the four cars and the boat were Epstein?s but that they-5.2 were regist-7.6ered in i.e Visoski?s nam The cars are a Land Rover/Range Rover-7 Case Document Entered on FLSD Docket Page of CASE NO Sport that Epstein purchased in the la st year a Mercedes Benz CLK Jaguar and a Ford The Ford apparently being kept on St Thomas-5 Island Visoski was not aware that the Fo rd was registered in his name although he was aware of the other vehicles that Epst ein registered in his Visoski?s name addition Visosk-5i now has-5 a 35-foot JV Powerbo-3.9a1.2t Visoski indicated that the owner of the boat LSJ LLC LSJ stands fo Little St John?s Island and the LLC is controlled by Epstein The boat is now registered in Visoski?s nam-7.4e addition Visosk-5.1i admitted that a Ferrari owned by Epstein is currently being in name for an pr-7.2ice The Ferrari is being-9 sold York wh-4.5ere Epst-7.9ein ma-4.5in-4.5tains residen-4.5ce website on Oct Visosk-5i di not the ca was being sold in his name and although he found it curious and strange that all these title conveyances-5.7 were taking place he did not questi on Defendant Epstein?s motives 2380Visoski also testified that he rece ived a Hummer automobile recently from Epstein 2684Jane Doe will provide the rele vant parts of Visoski?s te stimony to the Court when it becomes-5.5 available next week and will the Court to ons-5.2ider this newly--7.2discovered information in ruling on her motion for appointment of receiver to take control of Jeffrey?s-4.7 Epstein?s-5.4 assets Because Epstein has ently given notice to the Court that the6.8 motion for appointment of a rec-5.1e1.1iver been pending for roughly day-5s0 DE and has as-5ked for a prompt ruling on the motion Doe wanted to promptly alert Case Document Entered on FLSD Docket Page of CASE NO Court to thi7.2s0 new information B7e1.2cause th is new information provides additional evidenc-5.4e of on-going f-7.6r-2.4audulent transfers Jane Doe would join Epst ein and respectfully-5.1 request a on her motion for appointment of a receiver quick-5.4ly the Court-7.6 believes that it has the necessar-7.1y-.1 information to A quick is necessary avoid further concealment of assets by Epstein THE COURT SHOUL-5D1.4 REVIEW-7 MATERIALS FILED IN DOCKE-3.8T NUMBE-3.8RS In ruling on Jane Doe?s motion for appoint-7.5m ent of a receiver the Court should also cons-5.7ider additional dence not available at the ti me that Jane Doe filed motion materials provided by Epstein in camera in DE and DE the Court is awar-7.4e Jane Doe propounded reques-5ts for production requests for admission and interrogatories to Epstein to confess his fraudulent tr ansfer of assets Epstein refused to answer any-5 questions about as-4.7set transfe rs on Fifth Amendment grounds J-5ane Doe then filed motions to co mpel answers to these questions See DE DE and DE 2315Epstein filed responses to the moti to compel asserting that he confronted with a substantial an real threat of criminal prosecution if he an-4.2swered the questions-5 among others See DE DE and DE In connection with responses Epstein c-5.1r-2.1oss-referenced sealed ex parte submissions he made in other pleadings in c-5.1o1.1nsolidated Eps-5.1t ein repres-5.1ented that as set forth in more detail in DE and respo nding to the requests from in formation about his asset transfers w7.1ould reveal incriminating information See DE at Case Document Entered on FLSD Docket Page of CASE NO 2694Jane Doe now asks-5.6 the Cour to consider these two submissions not only-4.9 in connection with Epstein?s ar gument that he need not respond but also in connection with Jane motion for appoi ntment of a receiv-4.5er If it is true as Epstein represents that these seal ed submissions truly demonstr ates that responding questions about asset transfers poses a real risk of criminal pros-5.5ecut ion then that same information is obviously relevant to Jane Do e?s motion for appointment of a receiver 2640There is of course no barrier to the Court considering that in formation in rulin-5.2g on Jane Doe?s motion Epstein filed the do cuments under seal not to keep them from the Court but to keep them from Jane Doe Moreover there is no Fifth A6.9m-2.1endment prohibition to consider-7.4ing the information Ep stein has chosen to voluntarily reveal the information for his purposes in prevailing on his arg-4.1u1ments on his motion to compel.-7.4 The Court should be consider informa tion not only on that motion but on other-7.5 motions as well And in any event the Fifth Amendment does not apply in civil United States Scrivner F.3d 9th Cir U.S Cons-6.3t amend No person shall be compelled in any crim8.5inal case to be a witness-5.3 against him-7.2s-.2elf emphasis added 2625Finally common sense suggest-7.3s-.1 that the Court should cons-5.2ider-7.2 the information in ruling on Jane Doe?s motion for appointm ent of a receiver Any other-7 conclus-5i2.2on would ess-4.8entially mean that the Court would have to turn a blind eye to defendant who explains in a sealed subm ission how he is perpetrating an on-going fraud The Court should not bless-5.1 Epstein?s effort to hide his assets In stead it should c-5onsider all Case Document Entered on FLSD Docket Page of CASE NO of the information in the sealed submissi on and after doing so s-5.1hould prom-7.1ptly grant Jane motion for appointment of a receiver to prevent fr audulent transfer of assets CONCLUS-2.3ION all these reasons the Court shoul consider the additional information described in this pleading in support of Jane Doe?s motion for appointment of a receiver-7.2 to prevent fraudulent transfers of assets DATED October Respectfully Submitted Bradley Edwards Bradley Edwards ROTHST-5.3EIN ROSENFELDT Las Olas City Centre East Las Olas Blvd Suite Fort Lauderdale Florida Telephone Facsimile Florida No E-mail bedwards rra-law.com and Salt 2720Lake 2720City Telephone:-7.7 Facsimile:-7.7 E-Mail 110cassellp law.utah.edu Case Document Entered on FLSD Docket Page of CASE NO CERTIFICATE OF SERVICE HEREBY CERTIF-4.3Y t-7.3hat on October I e-3.6l2.5ectronically filed the foreg-3.6o1.5ing document with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all part ies on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF or in some ot-6.9her authorized manner fo those parties who are not authorized receive electronically filed Notices of Electronic Filing Bradley Edwards Bradley Edwards SERVICE LIST Jane Doe Jeffrey10.8 Epstein United States District Court Southern District of Florida Jack Alan Goldberger-7.5 Esq Jgoldberger agwpa.c-5.1o1.1m Robert Critton Esq rcritton bclcla-4.3w.com Isidro Manual Garcia isidrogarcia bells-5.2outh.net Jack Patrick Hill iph searc-5.7y-.7law.com Katherine Warthen Ezell KEzell podhurst.com Michael James Pike MPike bclclaw.com Paul Cassell cassellp Case Document Entered on FLSD Docket Page of CASE NO Richard Ho-4.5race Willits-5.7 lawyerswillits aol.com Robert Josefsberg rjosefsberg podhurst.com Adam Horowitz ahorowitz-5.6 5sexabus-5.6eattorney.com Stuart Mermelstein-4.1 ssm sexabuseattorney.com William Berger wberger rra-law.com Case Document Entered on FLSD Docket Page of
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