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Court Records as described by folder names.
Epstein Release Interview Victim Statements Evidence Maxwell
← Back to Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct. 2009)
Extracted Text

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facsimile Attorneys for Epstein SERVICE LIST CASE NO Jack Scarola Esq jsx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews Avenue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com Financial Plaza Suite Fort Lauderdale FL Chester Brewer Jr Esq wcblaw aol com wcbcg aol.com Chester Brewer Jr P.A One Clearlake Centre Suite Australian Avenue South West Palm Beach FL cont Epstein Rothstein et al Tonja Haddad Coleman Esquire Tonja tonjahaddad.com efiling tonjahaddad.com Law Offices of Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Attorneys for Jeffrey Epstein Epstein Rothstein et al Disposition Amount I I __ xt Inane ANAD ANSWER 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ORD-ORDER II Filing Date Filing Party I i ition Amount T-xt __ ON MOTION TO COMPEL-GRANTED AS STATED IN TEXT MCMP MOTION TO COMPEL Filing Date I mrn __ __ I Filing Party CRITTON JR I ESQ ROBERT DEWEESE sposition Amount Docket Text none i A_I OBJECTION Filing Date Filing Party I position Amount Docket Text i TO DFTS SUBPOENA REDACTED PER AGREED ORDER DTD mC"H yHO mOOMO gDate NOT NOTICE I II Filing Party EDWARDS BRAD Disposition Amount et Text none NOS NOTICE OF SERVICE Filing Date __ Filing Party CRITTON JR ESQ ROBERT DEWEESE isposition Amount ocket Text none __ MFPO MOTION FOR PROTECTIVE ORDER rFmng Date ng Party i position Amount cket Text TO HE_ O.EP_ SITION NAD_I MA OY II ii http://courtcon.co palm-beach fl.us pis iwp ck_pu bl ic_qry _doct port?backto case_id XM beg in_date en d_date Page of ll II NOS NOTICE OF SERVICE I II Date i I Filing Party I Disposition Amount et Text OF PLTS ANSWERS TO DFTS THIRD INTERROG MCMP MOTION TO COMPEL _J te I mng Party EPSTEIN JEFFREY __ Disposition 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TTORNEY EDWARDS BRAD AD KEYSER JUDGE PM Aliases ii Aliases I none Aliases nonel Aliases I none http courtcon.co palm-beach fl.us/pls/jiwp ck_public_qry _r 8XMB begin_date end_date Page of EXHIBIT Not an Official Document I ii II II I ATTORNEY I al i I I Docket Entries Docket Number ATTORNEY JUDGE AB Docket Type ADDITIONAL COMMENTS a te Party osition Amount Docket Text none CAFF Filing Date __ Filing Party E,W Disposition Amount Docket Text jnone PE PENDING iling Date mng Party isposition Amount I II PM GREGORY I II__ __ I CRITTON JR ESQ I Aliases I none I ROBERT DEWEESE nrnn,-nrn KELLEN SARAH Aliase GOLDBERGER ESQ Aliases JACKA nc 267omH 225nn,oum GILLEN JUDGE Aliases lnonel JEFFREY DANA Book and Page No Attached To http://courtcon.co palm-beach fl.us pls/jiwp/ck_pu blic_q ry_doct.cp report?backto case_id begin_date end_date Page of Not an Official Document PM Filing Date Filing Party isposition Amount xt none CCS CIVIL COVER Not an Official Document PM J7 I SMIS SUMMONS ISSUED II II 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tisposition Amount ocket Text TO QUASH PL TS NOTICE OF TAKING DEPOSITION NOF NOTICE OF FILING Filing Date Filing Party CRITTON JR ESQ ROBERT DEWEESE Docket Text AFFIDAVIT OF JACK A GOLDBERGER ATTACHED NOTICE OF HEARING ing Date Party CRITTON JR ESQ ROBERT DEWEESE Disposition Amount Docket Text ON AM Filing Date Filing Party KELLEN SARAH sp_o i!io mou nt cket Text II Filing Date Filing Party CRITTON JR ESQ ROBERT DEWEESE Disposition Amount MO Docket Text ON AM OBJ OBJECTION Filing Date Filing Party EPSTEIN JEFFREY Disposition Amount Docket Text TO NOTICE OF PRODUCTION AND SUBPOENA DUCES TECUM WITHOUT DEPOSITION DIRECTED TO YELLOW CAB I I I I http://couttcon.co palm-beach fl.us/pls/jiwp ck_public_qry_doct.cp report?backto case_id 58XMB begin_date end_date Page of Not an Officlal Document PM IL IIRCPT-RECEl FOR PAYMENT _JL II Filing Date Filing Party E,W Jisposition Amount ocket Text A Payment of was made on receipt RPRS-REPLVRESPONSE Date Filing Party EPSTEIN JEFFREY Disposition Amount I 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TRIAL Date Amount none Date sition Amount et Text none ORSH ORDER Not an Official Document PM Filing Date Filing Party EPSTEIN JEFFREY Disposition Amount Docket Text none NOTO-NOTICE OF TAKING I DEPOSITION i _J ling Date Filing Party _J Lr isposition Amount I Docket Text none I NOTO NOTICE OF TAKI NG DEPOSITION i ing Date ing Party sposition Amount I ocket Text none OT MOTION I Filing Date Filing Party EPSTEIN JEFFREY _J Disposition Amount I Docket Text FOR PARTIAL SUMMARY JUDGEMENT OSJT ORDER Not an Official Document PM II DEPOSITION JI _J Filing Date Filina Party CRITTON JR ESQ ROBERT DEWEESE isposition Amount I 2ocket Text DU TE RECORDS ONLY I SRSV SUBPOENA Not an Official Document PM I Filing Date __ I uw NO __ ng Party EPSTEIN JEFFREY I i Disposition Amount Docket Text none IRNOH RE-NOTICE OF HEARING Filing Date I Filing Party I Disposition Amount Docket Text JAN umm II ORD-ORDER Filing Date Filing Party isposition Amount Docket Text ON MOTION TO COMPEL-GRANTED-DHAFELE ummu,H __ __ I ORSH ORDER NO mng Party I Disposition Amount Docket Text none NOTICE OF JURY TRIAL ing Date _J jE __ I mng Party I Disposition Amount I Docket Text none NOS NOTICE OF SERVICE ng Date i Filing Party CRITTON JR ESQ ROBERT DEWEESE I http://courtcon.co.palm-beach eport?backto case_id BOS 8XMB begin_date end_date Page of Not an Official Document PM Amount i Docket Text 3RD Docket Text none NOS NOTICE OF SERVICE Filing Date Filing Party E,W P.!J itic Amount I I i I Docket Text llnone I http://councon.co.palm-beach fl.us pls/jiwp ck_public_qry _doct.c eport?backto case_id begin_date end_date Page of Not an Official Document PM NOTO NOTICE OF TAKING DEPOSITION i Filing Date Filing Party TTON JR ESQ ROBERT DEWEESE isposition Amount Jocket Text none NOTO NOTICE OF TAKING DEPOSITION te Filing Party HHrn NoM er rn Disposition Amount Docket Text OF E.W NOTO NOTICE OF TAKING DEPOSITION ling Date Filing Party Disposition Amount Docket Text TO R/C DR AMY SWAN I RESP RESPONSE TO I Filing Date Filing Party EDWARDS BRAD OUOL Disposition Amount Docket Text MOTION FOR PARTIAL SUMMARY JUDGEMENT NOS NOTICE OF SERVICE I Filing Date Filing Party EDWARDS BRAD _J Ill Disposition Amount I ket Text none REPLY/RESPONSE Filing Date Filing Party EPSTEIN JEFFREY mL Oispos_itio,n Amount I II http://courtcon.co palm-beach fl.us pls/j iwp/ck_pu blic_qry_doct.c eport?backto case_id BXMB begin_date end_date Page of Not an Official Document PM TO MOTION FOR PARTIAL SUMMARY JJUDGEMENT cket Text DEPOSITION ft _JcR1TTON JR ESQ ROBE Disposition Amount Docket Text none NOTO NOTICE OF TAKI NG DEPOSITION ion Amount i ext SEE LIST NOTO NOTICE OF TAKING DEPOSITION iling Date Filing Party CRITTON JR I ESQ ROBERT DEWEESE ition Amount none OT-MOTION ate i a rty E_P_S_T_E_IN_,_J_E_F_F_R_EY sition Amount et Text FOR LEAVE TO SERVE ADDITIONAL INTERRS MP MOTION TO COMPEL EPSTEIN JEFFREY http I cou rtcon.co.pal m-beach fl us/pis jiwp ck_public_q ry _doct.c eport?backto case_id S8XMB begin_date end_ date Page of Not an Official Document PM ocket Text JlANS _ERS 4TH Not an Official Document PM II RNOH RE-NOTICE OF HEARING II II i _i_ng Dat I Filing Party I I sposition Amount ket Text __ __ I NOS NOTICE OF SERVICE Filing Date I Filing Party EDWARDS BRAD I Disposition Amount Docket Text none SRSV SUBPOENA Not an Official Document PM I _j ORSH ORD I A iimiiml Filing Date iling Party Disposition Amount Docket Text CALENDAR CALL ON CASE WILL BE Not an Official Document PM Docket Text 225-IrcASE FROMTRIAL Not an Official Document PM Docket Text ilON MDIS MOTION TO DISMISS jFiling Date I Filing Party IIEPSTEIN JEFFREY Disposition Amount Docket Text COUNTS I II OF THIRD AMENDED COMPLAINT WITH PREJUDICE SRNS SUBPOENA Not an Official Document ORD-ORDER Date Party Book Page PM I ket Text ADOPTING STIPULATION AND DISMISSING CASED HAFELE STIP STIPULATION iling Date iling Party __ sposition Amount cket_Text oF DISMISSAL http eport?backto case_id begin_date end_date Page of JANE DOE Plaintiff Vs UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80893-CIV-MARRA/JOHNSON JEFFREY EPSTEIN et al Defendant Related Cases PLAINTIFF JANE DOES NOTICE THAT ADDITIONAL EVIDENCE OF EPSTEINS FRAUDULENT CASE NO 08-CV-80119-MARRA/JOHNSON post a million bond to secure any potential judgment in this case DE in case no The motion alleged that Epstein was hiding hundreds of millions of dollars in assets in an effort to defeat any judgment that Jane Doe and many other victims of his child sexual abuse might obtain against him On July Epstein filed his response Without specifically denying any of Jane Does allegations of fraudulent transfers Epstein essentially argued that Jane Doe lacked any proof of such transfers DE Jane Doe filed a reply to Epsteins response on July DE But in addition to the information and arguments provided there Jane Doe now wants to alert the Court to newly-discovered evidence bolstering her arguments regarding Epsteins fraudulent concealment of his assets Yesterday October counsel for Jane Doe took the deposition of Larry Visoski who has been Jeffrey Epsteins personal pilot for approximately years flying for example Epsteins Boeing jet Visoski declared that in the last year Epstein has transferred to him four very valuable cars and a boat and registered them in his Visoskis name A transcript of the deposition will not be available until October But in view of the extreme relevance of this information to Jane Does pending-motion she wanted to advise the Court of the substance of this testimony immediately and will provide precise quotations from the deposition as soon as it is available While a precise transcript is not yet available counsel represents that during the deposition Visoski testified that the four cars and the boat were Epsteins but that they were registered in his i.e Visoskis name The cars are a Land Rover/Range Rover CASE NO 08-CV-80119-MARRA/JOHNSON Sport that Epstein purchased in the last year a Mercedes Benz CLK Jaguar and a Ford The Ford is apparently being kept on St Thomas Island Visoski was not aware that the Ford was registered in his name although he was aware of the other vehicles that Epstein registered in his Visoskis name In addition Visoski now has a 35-foot JVC Powerboat Visoski indicated that the owner of the boat is LSJ LLC LSJ stands for Little St Johns Island and the LLC is controlled by Epstein The boat is now registered in Visoskis name In addition Visoski admitted that a Ferrari owned by Epstein is currently being sold in his name for an asking price of The Ferrari is being sold in New York where Epstein maintains a residence See website visited on Oct Visoski did not know why the car was being sold in his name and although he found it curious and strange that all these title conveyances were taking place he did not question Defendant Epsteins motives Visoski also testified that he received a Hummer automobile recently from Epstein Jane Doe will provide the relevant parts of Visoskis testimony to the Court when it becomes available next week and will ask the Court to consider this newly-discovered information in ruling on her motion for appointment of receiver to take control of Jeffreys Epsteins assets Because Epstein has recently given notice to the Court that the motion for appointment of a receiver has been pending for roughly days DE and has asked for a prompt ruling on the motion Jane Doe wanted to promptly alert the CASE NO 08-CV-80119-MARRA/JOHNSON Court to this new information Because this new information also provides additional evidence of on-going fraudulent transfers Jane Doe would join Epstein and respectfully request a ruling on her motion for appointment of a receiver as quickly as the Court believes that it has the necessary information to rule A quick ruling is necessary to avoid further concealment of assets by Epstein THE COURT SHOULD REVIEW MATERIALS FILED IN CASE NO 08-CV-80119-MARRAIJOHNSON Jane Doe now asks the Court to consider these two sealed submissions not only in connection with Epsteins argument that he need not respond but also in connection with Jane Does motion for appointment of a receiver If it is true as Epstein represents that these sealed submissions truly demonstrates that responding to questions about asset transfers poses a real risk of criminal prosecution then that same information is obviously relevant to Jane Does motion for appointment of a receiver There is of course no barrier to the Court considering that information in ruling on Jane Does motion Epstein filed the documents under seal not to keep them from the Court but to keep them from Jane Doe Moreover there is no Fifth Amendment prohibition to considering the information Epstein has chosen to voluntarily reveal the information for his purposes in prevailing on his arguments on his motion to compel The Court should be consider the information not only on that motion but on other motions as well And in any event the Fifth Amendment does not apply in civil cases United States Scrivner F.3d 9th Cir See U.S Const amend No person shall be compelled in any criminal case to be a witness against himself emphasis added Finally common sense suggests that the Court should consider the information in ruling on Jane Does motion for appointment of a receiver Any other conclusion would essentially mean that the Court would have to turn a blind eye to a defendant who explains in a sealed submission how he is perpetrating an on-going fraud The Court should not bless Epsteins effort to hide his assets Instead it should consider all CASE NO 08-CV-80119-MARRA/JOHNSON of the information in the sealed submission and after doing so should promptly grant Jane Does motion for appointment of a receiver to prevent fraudulent transfer of assets CONCLUSION For all these reasons the Court should consider the additional information described in this pleading in support of Jane Does motion for appointment of a receiver to prevent fraudulent transfers of assets DATED October Respectfully Submitted Bradley Edwards Bradley Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre East Las Olas Blvd Suite Fort Lauderdale Florida Telephone Facsimile Florida Bar No E-mail bedwards rra-law.com and Paul Cassell Pro Hae Vice Salt Lake City UT Telephone Facsimile E-Mail cassellp law.utah.edu CASE NO 80119-MARRA/JOHNSON CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October I electronically filed the foregoing document with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF_ or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing Isl Bradley Edwards Bradley Edwards SERVICE LIST Jane Doe Jeffrey Epstein United States District Court Southern District of Florida Jack Alan Goldberger Esq Jgoldberger agwpa.com Robert Critton Esq rcritton bclclaw.com Isidro Manual Garcia isidrogarcia bellsouth.net Jack Patrick Hill iph searcylaw.com Katherine Warthen Ezell KEzell podhurst.com Michael James Pike MPike bclclaw.com Paul Cassell cassellp bclclaw.com Richard Horace Willits lawyerswillits aol.com Robert Josefsberg rjosefsberg podhurst.com Adam Horowitz ahorowitz sexabuseattorney.com Stuart Mermelstein ssrn sexabuseattorney.com William Berger wberger rra-law.com CASE NO 08-CV-80119-MARRA/JOHNSON Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO CASE NO 08-CV-80119-MARRA/JOHNSON Plaintiff vs JEFFREY EPSTEIN Defendant JANE DOE NO CASE NO 08-CV-80232-MARRA/JOHNSON Plaintiff VS JEFFREY EPSTEIN Defendant JANE DOE NO CASE NO 08-CV-80380-MARRA/JOHNSON Plaintiff vs JEFFREY EPSTEIN Defendant I Case Document Entered on FLSD Docket Page of JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant JANE DOE NO Plaintiff VS JEFFREY EPSTEIN Defendant JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80119-MARRAIJOHNSO CASE NO 08-CV-80381-MARRA/JOHNSON CASE NO 08-CV-80994-MARRA/JOHNSON CASE NO 08-CV-80993-MARRA/JOHNSON Case Document Entered on FLSD Docket Page of C.M.A Plaintiff vs JEFFREY EPSTEIN Defendant JANE DOE Plaintiff Vs JEFFREY EPSTEIN et al Defendants I DOE JI Plaintiff vs JEFFREY EPSTEIN et al Defendants I CASE NO 08-CV-SfJI 19-MARRAIJOHNSON CASE NO 08-CV-80811-MARRA/JOHNSON CASE NO 08-CV-80893-CIV-MARRA/JOHNSON CASE NO 09-CV-80469-MARRA/JOHNSON Case Document Entered on FLSD Docket Page of JANE DOE NO I Plaintiff vs JEFFREY EPSTEIN Defendant JANE DOE NO Plaintiff VS JEFFREY EPSTEIN Defendant I CASE NO 09-CV-80591-MARRA/JOHNSON CASE NO 09-CV-80656-MARRA/JOHNSON PLAINTIFF JANE DOES REPLY MEMORANDUM IN SUPPORT OF MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAJJOHNSON is making them Because he has failed to controvert Jane Does claims they are deemed admitted Second in any event Jane Doe has clear evidentiary support that Epstein is hiding his assets through an adverse inference from his Fifth Amendment invocations That inference is entirely appropriate in this case because Epstein has personal knowledge of the subject at hand whether he is fraudulently transferring assets and the inference is entirely reasonable on the facts of the case Third in addition to the adverse inference Jane Doe has a perfect circumstantial case of fraudulent transfers Epstein has the means motive and opportunity to hide his assets In view of this proof of fraudulent transfers Federal Rule of Civil Procedure guarantees Jane Doe all available state law pre-judgment remedies to protect her interests Florida has adopted the Florida Uniform Fraudulent Transfer Act FUFT A Fla Stat Ann I et seq which gives the Court power to appoint a receiver to take charge of assets that are being fraudulently transferred Epsteins argument that this Court lacks the ability to make such an appointment conflates an ordinary case where courts are reluctant to take control of a defendants assets before entry of judgment and a case in which fraudulent transfers have been proven in which case seizure of assets is entirely appropriate Given that the Court has the power to appoint a receiver it should appoint a receiver Jane Doe has advanced extremely serious allegations of sexual abuse against Epstein which is likely to produce a substantial judgment in her favor not to mention judgments of a similar nature in several dozen other cases This Court should not allow Epstein to move hundreds of millions of dollars overseas before Jane Doe can obtain her judgment but should instead appoint a receiver now to take control of Epsteins assets and to post a million bond with this Court on behalf of Epstein to satisfy any judgment that Jane Doe might obtain DEFENDANT ESPTEIN HAS NOT DISPUTED JANE DOES MATERIAL FACTS WITH HIS OWN MATERIAL FACTS SO JANE DOES FACTS SHOULD BE ACCEPTED Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAIJOHNSON In her moving papers Jane Doe provided specific material facts each supported by evidence In response Epstein choose to ignore most of the facts resorting instead to generalized attacks that the facts are irrelevant speculative and hearsay Epsteins Memo in Opp DE at Epstein should not be permitted to proceed in this blunderbuss fashion Epstein should be required to explain which of the specific facts he disputes and which he does not Indeed his failure to controvert the facts specifically should lead the Court to deem all of them admitted A specific response to each of Jane Does material facts is certainly the approach envisioned in this Courts rules Local Rule explains that for summary judgment motions that statements of material facts shalt correspond with the order and with the paragraph numbering scheme used by the movant Additional facts shall be numbered and placed at the end of the opposing partys statement of material facts Id The rule concludes that all material facts set forth in the movants statement filed and supported as required by Local Rule will be deemed admitted unless controverted by the opposing partys statement provided that the Court finds that the movants statement is supported by evidence in the record Id The obvious underlying reason for this point-counterpoint approach is to narrow the range of disputes presented to the court A party needs to provide a specific basis for contesting the proposed facts of the other side and without such a basis should not contest the fact Epstein has short-circuited this process by refusing to explain which of Jane Does facts he contests and which he admits Obviously some of Jane Does facts are incontestable For example Jane Doe has asserted that she seeks more than million in damages and many other similarly-situated defendants seek at least the same amount in similar lawsuits pending before this Court and Florida courts Thus Epstein is facing more than billion in damages claims See Material Facts I and If these facts are true AM Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAIJOHNSON mdeniable motive to fraudulently hide his assets But Epstein sidesteps and refusing to say whether or not he disputes these quite incontestable facts Doe has alleged that Epstein has international contacts having travelled nous persons as President Bill Clinton Prince Andrew and Donald Trump Is he has these international travels Here again it is impossible to tell because 1ed whether he is contesting or accepting these facts several of Jane Does facts Epstein responds generally that they are supported tion For example Epstein argues this appearance of extreme wealth and national financial matters is based on inadmissible hearsay Epsteins at Epstein does not deny the truth of these allegations And to the extent urces for these claims are inadequate Jane Doe has now filed a motion to ting evidence with a new recently-obtained Declaration from Epstein himself es Motion to Provide Recently-Obtained Affidavit of Jeffrey Epstein in acts Supporting Motion for Appointment of a Receiver to Take Charge of This Declaration was signed by Esptein in October of and filed in fom of Law in Opposition to Plaintiffs Motion for Summary Judgment filed in NA Jeffrey Epstein and Financial Trust Company Inc Index No nited States Southern District of New York in which Epstein was named sident and Director of Financial Trust Co Inc as Defendant A copy of the rovided to Defendant and is attached hereto as Exhibit A In this Declaration penalty of perjury is President and Director of Financial Trust Company Inc a business that financial and business consulting services from the U.S Virgin Islands to its Case then Epstein has an obscures this point by Similarly Jan overseas with such fa Epstein contesting tha Epstein has not explai1 With regard to by hearsay informa sophistication in inter Memo in Opp DE that the supporting sc supplement her suppor See Plaintiff Jane Do Support of Material I Property of Epstein support of a Memoran the matter of Citibank Civ SHS in individually and as Pn Declaration has been Epstein declares under That he provide clients Case Document Entered on FLSD Docket Page of CASE NO 08-CY-80119-MARJUIJOHNSQN That he has been a legal resident of the U.S Virgin Islands since residing at Little St James Island a 70-acre island that he owns through a wholly-owned limited liability company From through the date of the affidavit Epstein was one of Citibanks most important individual clients In Epstein and Citibank did a IO mil I ion deal together followed by another similar million deal the next year These deals involved Epstein borrowing million from Citibank and then immediately reinvesting them in a fund that Citibank was touting Of course all of these admissions fully support the claims that Jane Doe made in her initial moving papers Presumably the reason for Epstein refusing to respond point-by-point to Jane Does facts is that he does not want to have to respond specifically to Jane Does position that he has fraudulently transferred assets in the past and is currently transferring his assets overseas transfers that are being used to defeat any judgment that might be entered against him in this case If Epstein were required to go point-by-point through Jane Does facts as the Local Rules envision then Epsteins counsel would have to either sign a pleading admitting that such fraudulent transfers are taking place or representing as an officer of the court that no such transfers are taking place Far better Epstein has apparently concluded to simply duck the issue entirely by blustering in general about how some aspects of Jane Does are speculative or irrelevant Because of Epsteins failure to provide specific material facts in opposition to the facts proffered by Jane Doe all of these facts should be taken as admitted JANE DOE HAS PROVIDED SUFFICIENT UNREBUTTED PROOF THAT EPSTEIN IS FRAUDULENTLY TRANSFERRING it Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAIJOHNSON led To the extent that any of the information provided in the lem has now disappeared in view of the Declaration signed by Court fraudulent transfers of assets overseas are also sufficiently ti rule Jane Doe supported her allegations on this point with ourt Local Rule namely Epsteins answers to her ries When asked directly whether he was perpetrating such a lment privilege against self-incrimination i the Court to draw the obvious adverse conclusion that he is overseas Epstein concedes that the Court has the power to Memo in Opp at He gamely maintains however that such for the test laid out by United States Custer Battles LLC rong test for deciding whether a factfinder can appropriately ing is whether there is a valid basis for asserting the privilege mked during discovery this validity issue is typically resolved the burden rests squarely on Epstein to show the specific basis Jrrently-pending motions to compel answers to her requests for nd interrogatories See e.g Plaintiff Jane Does Motion to quest for Admissions to Defendant DE filed July tion to compel the Court concludes that Epstein does not have 1ut asset transfers then Epstein will have to explain where he tion can be resolved in light of specific explanations from Case oocume Cassell Esq that Jane Doe initially Cassell affidavit was hearsay that pro Epstein that Jane Doe is providing to ti The facts regarding Epsteins supported As envisioned by the loc specific materials on file with the requests for admissions and interrogati fraud Epstein invoked his Fifth Amenc Epsteins invocation should lea in fact fraudulently transferring asset draw such an inference See Epsteins an inference is somehow not proper urn F.Supp.2d E.D Va Custer Battles lays out a two-1 draw an adverse inference The first pre Id at When the privilege is in via a motion to compel Id Because for his invocation Jane Doe has filed admissions requests for production Compel Answers to Plaintiffs First ff after reviewing Jane Does a valid basis for invoking privilege ab has transferred his assets and this Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON Epstein If on the other hand the Court concludes that Epstein does have a valid basis for invoking privilege about asset transfers then the Court will have concluded that Epstein might be prosecuted in this country for making fraudulent transfers Custer Battles F.Supp.2d at The issue then arises about what the court should infer from this fact The second-prong of the Custer Battles test explains how the Court should resolve whether to draw the obvious inference against Epstein The Court should make an assessment of whether the requested inference which is a fonn of evidence complies with the Federal Rules of Evidence Thus any adverse inferences must be relevant reliable and not unfairly prejudicial confusing or cumulative Id at internal citation omitted quoted in Epsteins Memo in Opp DE at Surprisingly having set out this governing second prong of the test Epstein does not pause to analyze whether it is satisfied Presumably that is because the test obviously is satisfied The inference that Epstein is fraudulently transferring assets is plainly relevant to Jane Does motion to have the Court intervene to stop the fraud The inference is likewise reliable because Epstein makes no argument nor offers any evidence to the contrary And the inference is clearly not unfairly prejudicial confusing or cumulative because it goes to the central issue in this motion The Fifth Amendment Cases Do Not Require Independent Evidence Before An Adverse Inference Can Be Drawn Rather than analyze whether the inference satisfies the two-prong Custer Battles test Epstein pulls another sentence out of context from the opinion which he claims fonns yet a third prong of what Custer Battles itself describes as a two step inquiry Id at Epstein argues that an adverse inference can only be drawn when independent evidence exists of the fact to which the party refuses to answer Epsteins Memo in Opp DE at But that is not what Custer Battles actually says Instead Custer Battles discusses the need to show through independent evidence that an adverse inference satisfies the requirement of personal knowledge one of the requirements for admissible Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON case explains This finding of personal knowledge must itself nted at trial a conclusion as to the reliability of an inference vtorris the defendants seemingly blanket invocation of the uster Battles F.Supp.2d at emphasis added Thus 1g inferences about other people state of mind via an adverse cation of his Fifth Amendment rights But the Court had no regarding Morris own state of mind This need for proof of ere as none of the six deposition questions as to which Morris which there is any doubt about Morris personal knowledge about Epsteins personal knowledge about whether he himself hich is the narrow question that Jane Doe propounded in her adverse inference would be entirely reliable and proper in this also citations in support of his claim that Jane Doe must jence of his fraudulent transfers in order to gain the inference irgan Hull 2d I I th Cir in which 267suit appealed from a district court decision granting summary in that case had attempted to defeat summary judgment by had not complied with discovery and invoked the Fifth 1estions during discovery The Eleventh Circuit however the fact that several defendants had raised Fifth Amendment 1mmary judgment grant Invocation of the fifth amendment cognizable inferences sufficient to preclude entry of summary Case Docume evidence under Fed Evid Th rely on the other evidence to be pres cannot derive by bootstrapping from privilege against self-incrimination Custer Battles cautioned against drawi inference from defendant Morris invc difficulty in finding an inference prope personal knowledge is not a problem took the Fifth inquire into matters as Id So too here There can be no doub is fraudulently transferring assets requests for admission Accordingly a1 case Epstein also provides two set provide some kind of independent evi1 of fraudulent transfers The first is Av Plaintiffs who had filed a frivolous lav judgment against them The plaintiff arguing that several of the defendan Amendment in response to certain rejected that claim by explaining that objections to discovery did not bar a privilege did not give rise to any legall case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON judgment The negative inference if any to be drawn from the assertion of the fifth amendment does not substitute for evidence needed to meet the burden of production Most importantly Avirgan and Honey did not demonstrate that further discovery would have led to evidence which would have precluded summary judgment Id at citing United States Rylander U.S Avirgan thus stands for the unexceptional proposition that the mere fact that someone has raised the Fifth Amendment does not prevent them from filing a well-supported summary judgment motion That principle has little application however to this case here it is Jane Doe who is the moving party Epstein has not provided any evidence that the Court should not draw an adverse inference or indeed any evidence at all in opposition to her motion Accordingly Avirgan is not on point and certainly does not suggest that Jane Doe needs to provide some sort of independent evidence to obtain an adverse inference The other case cited by Epstein Eagle Hospital Physicians LLC SRG Consulting Inc F.3d I th Cir is likewise unavailing There a defendant presented an affidavit to the district court that attached attorney-client privileged e-mails of the plaintiff company When the company deposed the defendant in an effort to learn how he obtained these sensitive documents the defendant took the Fifth Based on these facts alone the district court drew the adverse inference that the plaintiff maintained the ability to monitor the companys confidential e-mails On appeal the Eleventh Circuit affirmed the district courts decision to draw an adverse inference The Circuit explained that the decision to invoke the Fifth Amendment does not have to be consequence-free Id Instead a court need only avoid an undue burden on the constitutional invocation An undue burden would exist from tJhe automatic entry of an adverse judgment solely as a result of the In addition as explained below Jane Doe has independent evidence via the circumstantial evidence of fraudulent transfers that she has provided to the Court specifically the means motive and opportunity evidence Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAJJOHNSON at Similarly a dismissal following the assertion of the Jtion where the inferences drawn from the Fifth-Amendment tute for the need for evidence on an ultimate issue of fact Jd either the automatic entry of an adverse judgment or a ultimate fact Rather Jane Doe asks this Court to draw the is fraudulently transferring assets That adverse inference then asking not for ultimate entry of final judgment in her favor but iver over Epsteins assets to preserve the status quo and prevent he end of the case after paying whatever judgment the jury over his remaining assets Therefore drawing the inference as urden Epstein with any conclusion of ultimate fact but instead Hospital assign the proper evidentiary weight to Epsteins an draw an adverse inference on the facts of this case is also xceedingly difficult for Jane Doe to get information about has previously recognized that in the fraudulent transfer I to the plaintiff is more likely to possess the particularized nduct Special Purpose Accounts Receivable Co-op Corp S.D Fla Marra Obtaining infonnation ts is particularly difficult given his financial sophistication in ee e.g Declaration of Jeffrey Epstein Attachment I at I Island in the U.S Virgin Islands through a wholly-owned in the Virgin Islands Therefore the Court should draw the Case Docume assenion ofthe Fifth Amendment Fifth Amendment violates the Consti protected silence are treated as a subst Here Jane Doe does not prop dismissal based on a conclusion of specific adverse inference that Epstein becomes a link in a chain of reasoning rather for interim appointment of a rect any further fraudulent transfers At returns Epstein will then regain contro pan of resolving this motion does not does no more than was done in Eagle silence Id at The conclusion that the Court supported by common sense It is Epsteins assets Indeed this Court context the defendant as oppose information about the complained of cc Prime One Capital Co L.L.C about the whereabouts of Epsteins asi structuring control over those assets noting ownership of of Little St Ja1 limited liability company itself residen Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAIJOHNSON obvious inference that the reason Epstein is taking the Fifth when asked about his fraudulent transfers of assets is because he is making fraudulent transfers of assets ln Any Event Jane Doe Has Provided Circumstantial Evidence of Epsteins Frautlulent Transfers Even assuming for sake of argument that these cases could be read as establishing some sort of requirement that Jane Doe produce independent evidence of fraudulent transfers before obtaining an adverse inference Jane Doe has produced that evidence As explained in detail in her moving papers Jane Doe has a perfect circumstantial evidence case that Epstein hasJ means motive and opportunity to fraudulently transfer assets Jane Does Motion to Restrain Fraudulent Transfer of Assets at quoting United States Sparks F.3d th Cir Epstein completely misses the point of Jane Does means motive and opportunity argument construing it as some sort of new test for deciding whether asset transfers are fraudulent See Epsteins Memo in Opp at DE at But Jane Doe offers this circumstantial evidence not as a test for determining a fraudulent transfer but as evidence that Epstein is making fraudulent transfers Epstein cannot plausibly deny that he has the means motive and opportunity to move all of his substantial assets overseas beyond the reach of Jane Doe This circumstantial evidence should be more than enough to meet whatever sort of burden of production Epstein wants to tease out of the adverse inferences cases Indeed taken to its logical conclusion Epsteins argument about Jane Does purported need to provide independent evidence of fraudulent transfers ultimately collapses under its own weight Epstein would apparently require Jane Doe to track down his fraudulent asset transfers to foreign countries providing documentation of these fraudulent transfers Of course if she had clear Epstein claims that the Sparks decision is completely inapposite because it concerns probable cause for an arrest rather than a fraudulent asset determination Epsteins Memo in Opp at But the legal principle at stake that circumstantial evidence can provide strong proof is the same regardless of the precise facts of the case Indeed if circumstantial evidence can be used at the basis for arresting a man and throwing him into jail as in Sparks then it would easily seem to provide a sufficient basis for the interim appointment of receiver to prevent fraudulent asset transfers Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAIJOHNSON documentation of these transfers there would be no need to rely on an adverse inference In other words Epsteins interpretation of the burden that Jane Doe must sustain to obtain an adverse inference would make the inference all but irrelevant Epsteins position also ignores the realities of this case As Jane Doe proffered in her statement of facts without direct response from Epstein Epstein has blocked all discovery in this and other related cases regarding his assets Jane Does Motion to Restrain Fraudulent Transfer of Assets at supported by uncontested affidavit of her legal counsel Jane Doe had further proffered that Epstein is a man of great financial sophistication id at a fact now undeniably supported by Epsteins own affidavit See Declaration of Jeffrey Epstein at Attachment I swearing under oath that Epstein provides financial advice from the U.S Virgin Islands in securities and other matters to his clients and that he is viewed by Citibank as one of its most important individual clients Given the fact that asset transfers can take place to such countries as Israel Switzerland and the Cayman Islands placing the burden on Jane Doe to document fraudulent asset transfers to such destinations effectively gives a green light to massive fraud a fraud that could ultimately total in the neighborhood of one billion dollars See Jane Does Motion to Restrain Fraudulent Transfer of Assets at DE at statement of material fact that Epstein is a billionaire The Fifth Amendment does not require such obtuse results Instead it permits the narrow and reasonable inference that Epstein is fraudulently transferring his assets permitting the Court to take appropriate remedial action Drawing an Adverse Inference Would Not Violate the Fifth Amendment Epstein also tries to argue that drawing an adverse inference on these facts would violate his Fifth Amendment rights Epstein contends that a judgment cannot rest solely upon a privileged refusal to admit or deny at the pleading stage Epstein Memo in Opp DE at I OJ quoting LaSalle Bank Lake View Seguban F.3d 7th Cir emphasis added As just Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAIJOHNSON explained Jane Doe has circumstantial evidence of fraudulent transfers But more important for purposes of this argument Jane Doe is not asking for a final judgment to be entered on Epsteins fraudulent transfer of assets Instead she is asking merely for an adverse evidentiary inference that then becomes a piece of evidence supporting her motion turn her motion merely asks for an interim measure that would protect the status quo a receiver to account for Epsteins assets and prevent him from hiding them overseas Blocking fraudulent transfers is hardly the sort of coercive practice that is of concern in the cases cited by Epstein The cases are clear that using the Fifth Amendment to block discovery need not be cost free McKune Lile U.S Here there is no real cost to Epstein from the appointment of a receiver All Jane Doe wants is a receiver to control Epsteins assets to keep them from dissipating overseas and to post a bond in an interest-bearing account to satisfy any judgment that she might obtain These measures will only harm Epstein if he is attempting to fraudulently transfer his assets outside the reach of the Court This is not the sort of burden that might even conceivably implicate true Fifth Amendment concerns Jane Doe Has Met the Elements to Obtain Relief Under Floridas Uniform Fraudulent Transfer Act Somewhat out of order Epstein argues in the tail end of his response that Jane Doe has failed to sufficiently prove fraudulent transfers under Floridas Uniform Fraudulent Transfer Act FUFT A Fla Stat I et seq Memo in Opp at DE at Epstein argues that a fraudulent transfer is proven where I a transfer of property has in fact occurred the property transferred belonged to the debtor the transfer occurred within certain statutory time periods and the debtor made the transfer with the intent to hinder delay or defraud creditors Memo in Opp at DE Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON at citing In re Leneve B.R Bkrtcy S.D Fla However Epstein does not grapple with the fact that Jane Doe has properly proven each of these four points with regard to the first factor transfer of property Jane Does Material Fact is that Epstein has conveyed money and assets in an attempt to insulate and protect his money and assets from being capture in civil lawsuits filed against him With regard to the second factor that the property belonged to the debtor Jane Does Material Fact and among others is that he is moving his assets which total more than billion according to Material Fact overseas With regard to the third factor that the transfers occurred within the appropriate time limits Jane Does Material Fact is that the fraudulent transfers have been taking place since he was incarcerated i.e since June and Material Fact I I is that they are going on currently This on-going activity obviously satisfies whatever applicable time limits may apply With regard to the fourth factor that Epstein made the transfers with the intent to hinder delay or defraud creditors Jane Does Material Fact is that Epstein has conveyed money and assets in an attempt to insulate and protect his money and assets from being captured in civil lawsuits filed against him and Material Fact is that Epstein is transferring these assets with the intent to defeat any judgment that might be entered against him in this and other similar cases Plainly Jane Doe has covered the required elements of a case under the FUFT A There is thus no need for the Epstein incorrectly cites this case has having been decided by this Court the U.S District Court for the S.D of Florida when in fact it was decided by the Bankruptcy Court for the Southern District of Florida It is not clear that any time limit applies under the FUFT A The case cited by Epstein is a bankruptcy case which refers to the need to prove that the transfer was within one year of the date of the filing of the bankruptcy petition See In re Leneve B.R at citing In re Ingersoll B.R M.D Fla The FUFTA eschews any rigid time limit if it can be shown that transfer was made with the intent to hinder delay or defraud any creditor of the debtor Fla Stat Ann a Jane Doe has made such a showing as explained in the next paragraph in text For this reason Epsteins citation of In re Stewart B.R Bkrtcy M.D Fla is not on point In that case the plaintiff had merely made allegations without providing any supporting evidence Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAIJOHNSON Court to delve into the badges of fraud sometimes needed to determine fraudulent intent See e.g In re Dealers Agency Services Inc B.R Bkrtcy M.D Fla Courts use these badges of fraud because it is in some cases difficult to establish a transferors actual intent In re Ramsurat B.R Bkrtcy M.D Fla Here however Jane Does material facts establish the fraudulent intent It could hardly be otherwise Epstein has not alleged much less proven that he is moving his assets to overseas for any legitimate business purpose assets For all these reasons the Court should conclude that Epstein is fraudulently transferring his JANE DOE IS ENTITLED TO RELIEF TO BLOCK EPSTEINS FRAUDULENT TRANSFERS UNDER THE UNIFORM FRAUDULENT TRANSFER ACT AS ADOPTED BY FLORIDA In light of Epsteins fraudulent asset transfers Jane Doe is entitled to pre-judgment remedies to protect her For purposes of navigating through the Courts PACER filing system Jane Doe has checked the injunction box in the automated system But as made clear in the body of Jane Does motion while the relief can be viewed as a form of injunctive relief is more precisely viewed as a pre judgment seizure of property In any event the name is not important See Rosen Cascade Intern Inc F.3d 11th Cir federal courts look past the terminology to the actual nature of the relief requested internal quotation omitted Jane Does requested relief is specifically authorized by Federal Rule of Civil Procedure which guarantees Jane Doe during the course of unlike Jane Doe who has provided an affidavit of counsel adverse inferences from discovery propounded to Epstein and circumstantial evidence of the mean motive and opportunity for fraudulent transfers Moreover in Stewart that plaintiff did not allege any specific fact which even if admitted would support a finding that transfer was made with the actual intent to defraud a creditor Id at Here of course that is precisely what Jane Doe has alleged and proven all without any denial from Epstein Because Jane Doe is proceeding under Fed Civ Seizure of Person or Property rather than Fed Civ Injunctions she has not organized her brief around the well-known four factor test for obtaining injunctive relief At the same time however her moving papers specifically discuss each of the four factors and it is obviously that she easily satisfies them First Jane Doe has shown a likelihood of success on the merits As explained in her moving papers see Jane Doe Motion at at trial she and several dozen young girls will all testify to a pattern of sexual abuse by Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON this suit all remedies providing for seizure of person or property for the purpose of securing satisfaction of the judgment ultimately to be entered in the action that are available under the circumstances and in the manner provided by the law of the state in which the court is held The Rule goes on to provide that the remedies thus available include arrest attachment garnishment replevin sequestration and other corresponding or equivalent remedies however designated and regardless of whether by state procedure the remedy is ancillary to an action or must be obtained by an independent action This long-settled federal law provides that in all cases in federal court state law is incorporated to determine the availability of prejudgment remedies for the seizure of person or property to secure satisfaction of the judgment ultimately entered Rosen F.3d at Accordingly under this Rule this Court looks to Florida law to determine Jane Does rights to pre judgment relief To prevent fraudulent transfers of assets before judgment Florida has adopted the Uniform Fraudulent Transfer Act Fla Stat Ann et seq Under Floridas Uniform Fraudulent Transfer Act FUFT A courts are broadly empowered to take action to block fraudulent transfers of assets Epstein attempts to obscure the power of this Court to block his fraud by arguing to the Court that freezing a defendants assets to establish a fund with which to satisfy a potential judgment for money damages is not an appropriate exercise of a federal district courts authority Mem in Opp Epstein Epstein has pied guilty to abusing some of these girls and has invoked the Fifth Amendment rather than answer any questions about it Second Jane Doe will obviously be irreparably harmed if Epstein succeeds in fraudulently transferring his assets beyond the reach of this Court has she will be unable to satisfy any judgment that she might obtain against him Third this injury clearly outweighs any injury to Epstein as Epstein has not explained how he would he in any way harmed by the existence of a receiver whose job is merely to account for assets and block fraudulent transfers Finally such an injunction would serve the public interest as it would prevent a billionaire sex offender from depriving lane Doe and his other victims of compensation for the abuse he committed against them Because Jane Doe is proceeding under Fed Civ there is no requirement that she engage in a paper chase by filing some sort of separate state law claim as Epstein seems to argue Mem in Opp at See Rosen F.3d at Rule commands that the proper pretrial remedy to ensure that a fund will be available with which to satisfy a money judgment is available according to the provisions of the forum states law Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON DE at citing Rosen Cascade Intern Inc F.3d 11th Cir But Jane Doe stands not in the position of an ordinary tort claimant who is merely trying to gain a leg up on the collection of an anticipated judgment instead she is trying to block Epstein from altering the status quo by hiding all of his assets The difference between trying to gain an advantage in the collection process versus blocking fraudulent transfers is widely recognized in the case law For example Epsteins lead case Rosen Cascade Intern Inc F.3d 11th Cir refused to approve a pre-judgment injunction seizing assets where the plaintiff had merely argued that this would help in collecting a judgment down the road The Eleventh Circuit specifically recognized that fraudulent transfers of assets presented an entirely different problem Contrary to plaintiffs assertion our holding that a district court is without the power to grant such preliminary injunctive relief does not mean that a federal court is powerless to protect a potential future damages remedy against a recalcitrant defendant with highly liquid assets no matter how wrongful its conduct how bad the injury it caused or how brazen its attempt to evade judgment by secreting assets On the contrary Rule of the Federal Rules of Civil Procedure authorizes the prejudgment attachment of property for the benefit of a plaintiff in certain situations and provides the proper vehicle for plaintiffs seeking to restrain a defendants assets with an eye towards satisfying a potential money judgment 3d at In this case of course Jane Doe is face with a brazen attempt by Epstein to hide his assets She has responded by proceeding under Rule which Rosen calls the proper vehicle for plaintiffs in her position Equally off point is Epsteins other main case De Beers Consol Mines United States U.S in which the Government disclaim fed any benefit of Federal Rule of Civil Procedure which provides for an attachment during the course of an action for the purpose of securing payment of any judgment emphasis added Here of course far from disclaiming use of Fed Civ Jane Doe is proceeding under it The apparent reason that the Government Case Document Entered on FLSD Docket Page of CASE NO 19-MARRAIJOHNSON disclaimed use of Rule in De Beers was that it was not seeking any sort of money damages See Hoxworth Blinder Robinson Co Inc F.2d 3rd Cir explaining why De Beers is a peculiar case that must be understood in its context In later cases the Supreme Court has not hesitated to approve relief to prevent fraudulent dissipation of assets that might be used to satisfy a judgment awarding money damages See e.g United States First National City Bank U.S approving a temporary injunction to prevent transferring assets abroad and distinguishing De Beers In one final attempt to obscure this Courts power Epstein cites Lawhon Mason So.2d Fla Ct App as rejecting plaintiffs motion to prohibit a defendant from transferring assets Mem in Opp at But the specific reason given for rejecting the motion was that the plaintiffs were not proceeding under the Uniform Fraudulent Transfer Act So.2d at Of course in this case Jane Doe is proceeding under Floridas Uniform Fraudulent Transfer Act incorporated as a state law remedy into Fed Civ For all these reasons the Court has the power to protect Jane Doe through the provisions of the FUFTA UNDER FLORIDAS UNIFORM FRAUDULENT TRANSFER ACT JANE DOE IS ENTITLED TO THE REMEDIES OF APPOINTMENT OF A RECEIVER TOT AKE CHARGE OF EPSTEINS Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON An injunction against further disposition by the debtor of the asset transferred Appointment of a receiver to take charge of the asset transferred or of other property of the transferee or Any other relief the circumstances may require Fla Stat Ann In response Epstein argues that this Court is powerless to appoint a receiver because section of the FUFTA refers to a receiver to take control of the asset transferred or of other property of the transferee But Epstein does not deny that the Court obviously has the power to appoint a receiver under section of the FUFT A which broadly confers power on court to award any other relief the circumstances may require For this reason it is not important that Jane Doe shoehorn her claim within section Instead she can rely on which is a catch-all phrase that allows courts to award other relief Freeman First Union Nat Bank So.2d Fla The intent of this provision was to facilitate the use of the other remedies provided in the statute id presumably including receivers since they are discussed in the statute The only question then is whether the circumstances here make the appointment of a receiver appropriate A receiver is the remedy that makes the most sense because the receiver can identify where Epsteins assets are and can prevent further fraudulent transfers Epstein does not even argue much less convincingly argue that appointment of a receiver is inappropriate Instead he dives off on a detour regarding the circumstances in which fiduciaries can obtain an equitable accounting See Memo in Opp at However those cases allow an accounting where the remedy at law is inadequate Florida So/Mare Systems Inc Columbia/HCA Helathcare Corp F.Supp M.D Fla citing Kee National Reserve Life Insurance Co F.2d 11th Cir If the Court denies Jane Does motion then she will be completely without any remedy to bar Epsteins fraudulent transfers leaving her with no A receiver to account for Epsteins assets also makes sense because there are more than twenty other plaintiffs with sexual abuse claims against Epstein who may be similarly situated to Jane Doe A receiver can block fraudulent transfers that would harm these victims as well Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAIJOHNSON remedy at law Moreover Epstein pretends that the only point of the receiver is to provide an itemized list of his assets as though this were a mere accounting exercise But the main point of the receiver is block further fraudulent transfers by exercising control over Epsteins assets Jane Doe will not be comforted to get an accounting next year after trial showing that Epstein has moved his hundreds of millions of dollars to Swiss bank accounts Israeli corporations and Cayman Island investment trusts Instead she wants a receiver appointed now to keep Epstein from fully perpetrating a billion-dollar fraud After the receiver is in place Jane Doe also asks for the posting of bond Here again Epstein quibbles about the Courts authority to order such an award without addressing the fact that this Court has broad power to give Jane Doe a ny other relief the circumstances may require Fla Stat Ann Such a bond is appropriate in the circumstances here particularly given that Epstein never contests Jane Does argument as to why such a bond is a reasonable given the judgment she is likely to obtain See Jane Does Motion to Restrain Fraudulent Transfer of Assets at DE at THE COURT ALSO HAS EQUITABLE POWERS TO PREVENT FRAUDULENT TRANSFERS For all the reasons just explained the Court has specifically direct power to appoint a receiver under the FUFT A But Jane Doe also explained in her motion that the Court has additional equitable powers As the Florida cases explain the UFTA grants the court equity powers to remedy fraud lnvo Florida Inc Somerset Venturer Inc So.2d Fla Ct Apps The FUFTAs provisions are supplemented by the principles of law and equity Fla Stat Ann Epstein does not contest Jane Does argument that equity will do what ought to be done Jane Does Motion to Restrain Fraudulent Transfer of Assets at citing Sterling Brevard County So.2d Fla Ct Apps The only question then is what ought to be done Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAIJOHNSON Epsteins answer to that question at least as can be inferred from his pleadings is that he should be allowed to take the Fifth on all questions about his sexual abuse of Jane Doe and where his assets are and then be left free to fraudulently transfer all of hundreds of millions of dollars of assets to such places as Switzerland Israel and tax havens in the Caribbean ultimately leaving Jane Doe unable to obtain any financial compensation for the abuse he inflicted on her and the financial losses that it he entails This Court should not allow such an affront to Jane Doe and other victims of Epstein a convicted sex offender not to mention the affront to the ability of this Court to enforce any judgment the jury might ultimately return When this Court proceeds in equity it will not suffer a wrong to be without a remedy Connell Mittendorf So.2d Fla Ct Apps Jane Doe asks for the straightforward relief of appointing a receiver to take control over Epsteins assets and make arrangement to prevent further fraudulent transfers Jane Doe has explained precisely how the receiver should operate providing a proposed order for the Courts consideration Epstein has not argued that the proposed order is burdensome in any way or suffers from any flaws Indeed the Court can read his entire response without finding any substantive reason why the Court should not take the obvious step of intervening to block fraudulent movement of his assets overseas Instead Epstein raises alleged legal roadblocks and procedural requirements that somehow keep the Court from doing what ought to be done For all the reasons explained here and in Jane Does opening papers the Court should do what equity demands It should reject Epsteins makeweight arguments and intervene to block Epsteins fraud by appointing a receiver to take charge of his assets CONCLUSION WHEREFORE in view of the fraudulent transfers being made by Jeffrey Epstein to prevent Jane Doe from satisfying any judgment she might obtain in this case the Court should appoint a Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JO/INSON receiver to take charge of Epsteins property and direct the receiver to provide the Court with an accounting of Epsteins assets and post a million bond to secure any potential judgment that Jane Doe might obtain in this case DATED July Respectfully Submitted Bradley Edwards Bradley Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre I East Las Olas Blvd Suite Fort Lauderdale Florida I Telephone Facsimile Florida Bar No E-mail bedwards m,rra-law com and Paul Cassell Pro Hae Vice Salt Lake City UT Telephone Facsimile E-Mail cassellp dlaw.utah.edu CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July I electronically filed the foregoing document with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing Bradley Edwards Bradley Edwards Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRAIJOHNSON SERVICE LIST Jane Doe Jeffrey Epstein United States District Court Southern District of Florida Jack Alan Goldberger Esq goldbergcr agwpa.com Robert Critton Esq rcri ttonr d;bclc law com Isidro Manual Garcia isidrogarciarWbellsouth.nlt Jack Patrick Hill iph Zvsearcy law com Katherine Warthen Ezell ls:.Ezell a podhurst.com Michael James Pike Pike Zi bclclaw com Paul Cassell cassellp bclclaw.com Richard Horace Willits lawyerswillits aol.com Robert Josefsberg riosef sberg/ivpodh urst.com Adam Horowitz ahormv itz sexabuscattorney.com Stuart Mermelstein ssm sexabuseatlorney com William Berger wberger d1rra-law.com Case Document Entered on FLSD Docket Page of PLAINTIFF JANE DOES REPLY MEMORANDUM IN SUPPORT OF MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ase Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CITIB N.A Plaintiff JEFFREY EPSTEIN and FINANCIAL TRUST COMP ANY INC Defendants Index No Civ SHS DECLARA ON OF JEFFREY EPSTEIN JEFFREY EPSTEIN declares under penalty of perjury pursuant U.S.C that th following is true-and correct I I am on of the Defendants in the above-captioned action and the sole shareholder the President and a Director of Defendant Financial Trust Company In FTCI and mllke this Declaration based upon my personal knowledge of lbe facts set forth herein I submit this Declaration in opposition to Plaintiffs Motion for Surnmary Judgment I have been a legal resident of the U.S Virgin Islands since I reside at Little St James Island in the U.S Virgin Islands which is an approximately acre island that have owned through a whollrowned limitcd-liebility company since I am stered to vote and have voted in the Virgin Islands i have a current and valid U.S Virgin Islands driver license and fkeanns license and maintain a personal bank account and IRA acco nt in the U.S Virgin Islands Through my wholly-owned limited liability company which is also resident in the U.S Virgin Islands I employ approximately people maintain two more bank accounts own two cars and three boats and maintain several telephone numbers all in the U.S Virgin Islands Case Document Entered on FLSD Docket Page of My only business is a U.S Virgin Islands coiponnion urg:.ini1.cd i1 the U.S Virgin lshmds in l9tJ9 us 225Financial Trns1 Company Inc FTC maini.iins its princi1,.t1 nm.I only llaec ul busin consisting of s1.1uare feet of offict spu in St Th mia Virgin ISltuids AU eleven of FiCls employees including myself are U.S Virgin lslumls residents FTCI is qunlitied underthe U.S Virgin Islands Economic De 267elorunent Commission as authorized under the laws of the U.S Vir in Islands FTC muintains lhree local bank accounlS a local IRA a cuunt um.t its books an records in the U.S Virgin islands Between May L9 and March FTCI muintained vo hank accounts with the St Thomas branch of Citibank FTCI is engaged in the business of providing timmcial nd business consulting scrdccs from the U.S Virgi11 Islands to its clients In connection with ils c,msuhing business FT I mukes investments in securities and other investments which we ri:-i1Y.n1 ably expect to be protilable and appropriate lor ourselves a.ml our clients My business dealings and relationship with Citigroup und its predecessor Citicorp date back to the I I became client of the Citibank Pri 267atc Bank in or about For approximately l5 yea.rs Citicorp Citibank and ultinmlely Ci1ig.mup provided hunking and tinanciul services to me and my business clients through the itihunk Private Bank which upon information and belief changed its name to the Citigroup Prinllc ink some time in co11ecth,ely tigroup the Private Bank The Citigroup rck1tionship mimuge responsible for these services duriug most of that period was Dayle Dnvison 9_ In early I leamed from Ms Davison an employ of the Privnte Bank _that Citigroup had targeted me as one of its most important individual clients and wi,s seeking lo Case Document Entered 0n FLSD Docket Page of capitalize on its longstanding,;relatioriship with me to persuade me to purchase a wide array of additional ial products and financial services which were now available from Citigroup Citibank began the hard-sell of their new products and services bi or arowid late April of J/hile I was in the U.S Virgin Islands At-that time Citibank first introduced me to what was characterized as an exceptional investment opportunity involving a fund to be managed by A..IO Global Investment Corp AIG In a series of telc;phone calls which I received in the U.S Virgin bland.s between on or about April and on or about 267May employees of the Private Bank including Ms Davison aggressively solicited my participation in this 253oppo Uity ultimately resulting in a substanti investment by FTCI in the amount of million 225AJG Investment D,uriog that period I remember teleph ne conversations with Ms Davison in whicJi she counsel me to subscribe for the AIG Investment She tpld me that it was an exceptional opportunity which has already generated so rnuch preliminary interest that-it will be subs ally over-subscribed Ms Davison told me that Citigroup was offerin_g this opportunity first to me as one the Private Bank most important CliCl;lts to ensure that have an opportunity to subscribe Nb Davison also stated in-essence that I wa.5 virtu Uy assured of receiving an-ts return on my investment vyith a possible return of as much as She further emphasized that Citibank really did their due diligence on this deal and was anticipating putting its own money in as an investor Finally Ms Davison made affinnative assurances regarding my ability to protect my interest in the investment she aovis that I should not wony because Citibwik was going to remain actively involved in the q.eal including possibly as an investor i I _e ocument Entered on FLSD Docket Page of In light Qf Ms Davisons statements regarding the exceptional merits of the AIG Investment and particularly the fact that Citibank was anticipating making its own investment in 267the deal I inquired whether Citibank was confident enough in the assurances Ms Davison had de to me to loan me the necessiuy funds for the AIG lnvestment After further discussion met Ms Davison and other representatives of FTCJ Citibank offered to loan me SI million on the express condition that the loan be used exclusively to fi.wd FTCIs investment in the AIO Iuvestrn did not need borrow the 267mon for FTCI to make ltle AIG Investment However Citibank offered thefoan at an interest rate subStantiaUy lower than the rate of the return that Ms Davison assured would re:.wlt from the AlO Investment Moreover Citibank promised to loan me the fund for the life of the AlO lnvestment Consequently on the basi:i of Ms Davisons assurances understood Citigroup to be offeri.f1g me as one of the Private Banks most important clients th opportUnity to use Citibanks money to fund an investment by FTCI in a transaction that was assured of yielding a substantial net positive return was backed by Citibanks ex.tensive due diligen and would-be protected by the continued involvement of Citibank wbi was anticipating ma.king an investment in the deal Under the circ_wnstances I could not refuse such an offer At some point prior to August of I was provided with a so--called Pitch ok promoting the AIG Investment I am certain that such materials did not contain any information that even remotely suggested to me that I had any reason to doubt Ms Davisons assurances or raise any concern that my long-st ding bankers and now ad-viso were not The loan was originally structured as a 0-year loan iJl order robe eotcnninous with the AIG Invcstmeut However Ms Davuon alke ine if Would noc mind mlCtUrinS tbc tom as a short-term 1oaJl because Bhe aid short-term loans are accounted for mare mvo.rabl,y on-the banks books than Jong term loans She assured me that Case Document Entered on FLSD Docket Page of acting in my or FTCIs best interests in recommending this investment To the contraxy I was persuaded by Ms Davison assurances that the Private Bank would be involvEMf in the deal including potentially as an investor Based upon all of the foregoing I decided to proceed with the transaction that had discussed with Davison and on or about August I executed a promissory note in the face amount of million in favor of Citibank the Nole and then with Private Bank"s knowledge and approval and as required by Citibank the loan proceeds we wired by Citibank to my Citibank account and then transferred to FTCIs Citibank account and then transferred to the bank account designated by Citibank for making the AIO Investment At a me point I also received an Offering Circular describing the AIO Investment Based upoq what I recall receiving understood that investors such as FTCI would have the right to the manager of the fund AIO by vote of a certain percentage of the investment or note holders This fact was very important to Jne since it represented the most signific.ant way in which FTCIs interest in the A!O ve51ment could be protected in the event that the fimd manager was not pursuing a favorable or successful investment strategy In fact I believed based upon Ms Davisons assurance that the Private Bank was going to be involved coupled with the fact that I understood thatCitibanks affiliate Salomon Smith Barney was acting as Placement Agent that if there was ever a.problem with the funds gemen4 in order to protect the collective inierests of FTCI Citigroups other important c::Henb and the Private Bank itself the Private Bank would have the ability to 267either influence the fund manager appropriately or amass the consent of the necessary int in the fund to promptly replace the fund manager the malUrily daw of the loon would be cxten.deid annually so that neither nor FTCl wou1d et havo to eome out of pocket in connection wf1b this invcstm nt Case Document Entered on FLSD Docket Page of During Ms Davison spoke td me about another similar inves_tment fund this one to be managed MassMutual the 225MassMutual Fund I understood bued upon my prior discussions with Ms Davison in that ere would be additional investment opportunities similar to the AlG Investment and further understood the MassMutual Fund co such an oppOrtunity There were negotiations between my representatives and legal advisors including while they and were in the U.S Virgin Islands and Ms Davison and other representatives of Citigroup including but not limited t.o the Private Bank concerning the MassMutual Fund Ultimately and based upon discussions substantially similar to those.that occurred in I borrowc another IO million from Citibank which funds were expr ly required to be contemporaneously used by me to fund FTCls investrn in the MassMutual Fuad Again signed a promissory note payable to.Citibank the Notej and the underlying funds were transferred from Citibank to my Citibank acc unt to FTCl account and then to the account designated by Citibenk for the investment in the Mass.Mutual Fund By the Spring of we tnade a sho king discovery Largely through thi review of monthly statements furnished by AIO we discovered that the AIG Investment was suddenly and rapidly deteriorating ata time when similarly-stru MassMutual Fund appeared to be perfonning as expected These inconsistent results suggested to me that the problems resided with the mamiger of the AIO Investment as opposed to ptevailing marlcet conditions.2 and that my bankers and advi rs at the Private Bank were not mOilitoting the progre of this fund as Ms Davison assured me would At my insistence in order protect FTCIs sizeable 267mvestment FfCls advisors promptly initiated comm cations with Ms Daviso!l and other employees of the Private Bank to I note that FTCI1 investment ln die MassMutual Fund now also ha drastically declined in value i I i I Case Document Entered on FLSD Docket Pages of share our concerns find out what was transpiring with the AIG Investment and to request that the Private Bank take action including coordinating the replacement of the fund manager I understand that Ms Davison initiaJly indicated to FTCIs representatives that she would cooperate with FTC in pursuing the removal of AlG as manager However subsequently learned the horrifying truth of Cit banks betrayal I was infonned that not only W1iS Ms Davison unable to timely provide ITCI wit.4 the infurmation we needed to punue a change of managers but that Citigroup/Citibank was unwilling to assist us at all since to do so would jeopardize an apparently more lucrative relationship that Citibanks affiliate SSB had with AIG Citibanks inability and ultimately unwillingness to assist FTCI in pursuing its rights in orda to protect its interests delayed FTCI from ectively pursu its rights to cliange the manager of the AlG Inv tment until such time that changing the manager would have been futile since the investment 1;apidly deteriorated to near zero Prior to had every reason to believe that the assurances_ on which I had based my decision to bonow the investment funds from Citibank and cause FTCI to subscribe for the AIG Investment were truthfill Prior to that time I was never was informed by Ms Davison or anyone else at Citigroup/Citibank and never learned through my review of any of the materials provided to me that Citigroup or Citibank or the Private Bank would in any way be unable or unwilling to assist me or FfCI in pursuing our rights with respect to the AIG lnvesnn Nor did ev_er leam prior to that SSB had an investment ban.lcing relationship with AIO much less a relationship that my bankers and advisors would hold in higher regard than my long-standing relationship with the Private Bank Case Document Entered on FLSD Docket Page of Had I known of these conflicts and the fact that the Private Banks advice and recommendation was impaired and tainted in such a meaningful way or that Ms Davisons assurances that Citibank would be involved in the deal we un rue in any way I never would have proceeded with ither the AIG Investment or the MassMutual Fund never would have executed either the Note or the Note and never would have caused FTCI to invest million in the investments that were being placed by SSB now understand that FTCIs interest in the AJO Investment is nearly worthless and further that FTCls interest in the MassMutual Fund has drastically decreased in value Case ocument Entered on FLSD Docket Page of For the fo going reasons and those set forth in the accompanying memorandum oflaw and other submissions made on my and FTCIs behal respectfully rtquest that the Coun deny Citibanks motion in its ntirety Executed this 267day of October Rothstein Rosenfeldt Adler Attorneys at Law July Via Facsmile Adam Horowitz Esquire Stuart Mennelstein Esquire Isidro Manuel Garcia Esquire Jeffrey Marc Herman Esquire Katherine Earthen Ezell Esquire Robert Josefsberit EsquiTe Jack Hill Esquire Dear Counsel Bmdtey ards Direct Dial bed ards na-htw.com We have recently received Notice for Depositions from Adam Il.orowitz for several witnesses ruui the lever from Jack Hill indicating an intent to take others We intend to Cross-Notice each deposition Additionally we intend to set the following other individuals for video depoi,;ition I I Donald Trump West Palm Beach Ole Dubin WestPalm Beach Ohlslain Maxwell New York Sara Keller New Yotk Leslie Wexner Ohio Bill Clinton D.C Paula-Heil New York Jean Luc Bruhel New York A Jr f.:XHJBIT Deponent ff/tf v_,J D:rte-Rptr.Qd:_ To Laa City Cantre OtH Jlevard suite Fort Lsud 225rdale f!iotlda Telepnone 9C Fax BOCA RATON FORT LAUDERDALE IIMMf NaW YORk CllY 267TALLAHASSEE WASHINGTON D.C WEST PALM BEACJ-1 July Page of We will choose dates that have not already been occupied by other depositions already set in this case If you would like to be included in the scheduling of these depositions please provide me with your scheduling secretaries names and mall addresses ff any of you do DQt need to be consulted regarding the scheduling of these depositions please advise me of that as wells Very truly yo Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I CASE NO 08-CV-80119-MARRA/JOHNSON CASE NO 08-CV-80232-MARRA/JOHNSON CASE NO 08-CV..S0380-MARRA/JOHNSON Case Document Entered on FLSD Docket Page of JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant JANE DOE NO Plaintiff VS JEFFREY EPSTEIN Defendant JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80119-MARRA/JOHNSON CASE NO 08-CV-80381-MARRA/JOHNSON CASE NO 08-CV-80994-MARRA/JOHNSON CASE NO 08-CV-80993-MARRA/JOHNSON Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON CASE NO 08-CV-80811-MARRA/JOHNSON C.M.A Plaintiff vs JEFFREY EPSTEIN Defendant __ JANE DOE Plaintiff Vs CASE NO os-ev aoagJ-CIV-MARRA/JOHNSON JEFFREY EPSTEIN et al Defendant __ DOE II CASE NO 09-CV-80469-MARRA/JOHNSON Plaintiff vs JEFFREY EPSTEIN et al Defendants Case Document Entered on FLSD Docket Page of JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80119-MARRA/JOHNSON CASE NO 09-CV-80591-MARRA/JOHNSON CASE NO 09-CV-80656-MARRA/JOHNSON PLAINTIFF JANE DOES MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON Epsteins property and to post a million bond to secure any potential judgment in this case Epstein is a billionaire who recently has been fraudulently transferring his assets overseas and elsewhere with the intent to prevent Jane Doe and possibly numerous other victims of his sexual abuse from satisfying any judgment they might obtain against him Federal Rule of Civil Procedure guarantees Jane Doe all available state law pre-judgment remedies to respond to these fraudulent transfers Florida has adopted the Florida Uniform Fraudulent Transfer Act FUFTA Fla Stat Ann et seq which gives the Court power to appoint a receiver to take charge of assets that are being fraudulently transferred Given the serious allegations of sexual abuse against Jane Doe when she was a minor this Court should appoint a receiver to control and account for Epsteins assets and direct the receiver to post a million bond with this Court on behalf of Epstein to satisfy any judgment that Jane Doe might obtain STATEMENT OF MATERIAL FACTS Defendant Jeffrey Epstein is the defendant in this action which involves claims by Jane Doe that Epstein repeatedly sexually abused her when she was a minor Because of the egregious and repeated acts of sexual abuse committed by Epstein her complaint seeks damages in excess of million including punitive damages See Amended Complaint Defendant Jeffrey Epstein is extremely wealthy According to reputable press reports in the New York Times and elsewhere he is a billionaire He is also the owner Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON of a Caribbean island in the Virgin lslands Little St James Island where he serves as a financial advisor to other billionaires He was previously a financial trader at Bear Stearns It is therefore reasonable to infer that he has a great deal of financial sophistication See Affidavit of Paul Cassell at Attachment A to this Pleading According to reputable press reports before his recent incarceration discussed below he frequently traveled around the globe in the company of such famous persons as President Bill Clinton Prince Andrew and Donald Trump It is therefore reasonable to infer that he has international contacts Including international financial contacts See Affidavit of Paul Cassell at Over the past year approximately civil suits have been filed in Florida state courts and Florida federal courts raising similar allegations of sexual abuse by Jeffrey Epstein against minor girls These complaints seek damages comparable to those sought by Jane Doe in this case See Affidavit of Paul Cassell at 1f Accordingly Epstein has currently pending against him lawsuits seeking more than billion in damages He thus faces financial ruin Id On June Jeffrey Epstein pied guilty to one count of procuring a person under for prostitution and one count of felony solicitation to prostitution before the Circuit Court of the Fifteenth Judicial circuit in and for Palm Beach County Florida He was sentenced to months in jail Since those guilty pleas he has been incarcerated in the Palm Beach County Detention facility However he has also been allowed out on a work release program where he works at managing his financial interests Affidavit of Paul Cassell at Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON Given the substantial claims against him his international connections and other information Jane Does counsel has been gravely concerned that Epstein will fraudulently transfer all of his assets to overseas locations to defeat collection of any judgment that she might obtain against him Accordingly as part of discovery in this case Jane Doe propounded requests for admissions by Epstein regarding whether he was fraudulently transferring assets Rather than answering these requests for admission about on-going fraudulent transfers of his property Jeffrey Epstein asserted his Fifth Amendment right against self-incrimination Affidavit of Paul Cassell at Jeffrey Epsteins net worth is greater than billion Jane Does First Request for Admissions RFAs Attachment to this Pleading Epsteins Resp to RFAs Attachment to this Pleading Since he was incarcerated Jeffrey Epstein has directly or indirectly through the services or assistance of other persons conveyed mone_y and assets in an attempt to insulate and protect his money and assets from being captures in civil lawsuits filed against him Epsteins Resp to RFAs Epstein owns and controls real estate property in foreign countries including the Caribbean Epsteins Resp to RFAs and Epstein is currently moving significant financial assets overseas outside of the direct territorial reach of federal and Florida courts Epsteins Resp to RFA Epstein is transferring these assets with the intent to defeat any judgment that might be entered against him in this and other similar cases Epsteins Resp to RFA Case Document Entered on FLSD Docket Page of CASE NO oa CV-80119-MARRA/JOHNSON Epstein could currently post a million bond to satisfy a judgment in this case without financial or other difficulty Epsteins Resp to RFA Epstein has blocked all discovery in this and other related cases regarding his assets Affidavit of Paul Cassell at r,r ARGUMENT I EPSTEIN IS FRAUDULENTLY TRANSFERRING HIS Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON Conjurers Circle The Fifth Amendment Privilege in Civil Cases YALE L.J As a result where a witness refuses to testify in a civil case on Fifth Amendment grounds the permissible inference is that the witnes testimony had it been given would not have been favorable to the claim United States A Single Family Residence F.2d 11th Cir Of course the Fifth Amendment is not violated by such an inference The concerns animating the Fifth Amendment right against self wincrimination are not in play in a civil suit involving only private parties because no party brings to the battle the awesome powers of the government and therefore to permit an adverse inference to be drawn from exercise of the privilege does not implicate the policy considerations underlying the privilege Baxter Palmigiano An adverse inference is entirely justified in this case Epstein has remained silent when asked such straightforward requests for admissions Since being incarcerated you have directly or indirectly through the services or assistance of other persons conveyed money or assets in an attempt to insulate or protect your money or assets from being captured in any civil lawsuits filed against you RFAs You are moving significant financial assets overseas outside of the direct territorial reach of the U.S and Florida Courts RFAs You are making asset transfers with the intent to defeat any judgment that might be entered against you in this or similar cases RFAs Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON The silence in the face of these questions speaks far louder than words As Justice Brandeis recognized long ago silence is often evidence of the most persuasive character Baxter Palmigiano U.S quoting U.S ex rel Bilokumsky Tod U.S This is plainly one of those situations In a civil case drawing an adverse inference is the proper action for a court to take when a litigant blocks legitimate discovery through exercise of a Fifth Amendment invocation While there is no doubt that a witness is entitled to assert the privilege in a civil case it is also clear that an adverse inference based on a refusal to answer in a civil case is an appropriate remedy as it provides some relief for the civil litigant whose case is unfairly prejudiced by a witness assertion of the Fifth Amendment privilege without placing the witness in the cruel trilemma of choosing among incrimination pe ury or contempt United States ex rel DRC Inc Custer Battles LLC F.Supp.2d E.D Va The Eleventh Circuit has not hesitated to support district courts that draw an adverse inference from silence For example in United States Two Parcels of Real Properly F.3d 11th Cir the district court drew an adverse inference when claimants to real property refused to answer questions regarding the property The Eleventh Circuit affirmed that decision explaining that this Court has held that the trier of fact may take an adverse inference against parties to a civil action refusing to testify on Fifth Amendment grounds Id at citing United States A Single Family Residence F.2d 11th Cir Similarly in Arango U.S Dept of the Treasury F.3d 11th Cir the Eleventh Circuit explained that Uthe First Amendment Case Document Entered on FLSD Docket Page of CASE NO MARRA/JOHNSON does not forbid adverse inferences against civil litigants who assert the privilege against self-incrimination Here an adverse inference is entirely appropriate In addition to Epsteins refusal to answer questions there are strong circumstantial reasons for believing he is hiding his assets As explained above see Statement of Material Facts through Epstein clearly has the means to hide his assets he is a sophisticated financial advisor And given that the sexual abuse lawsuits brought against Epstein threaten him with financial ruin he has a clear motive for hiding his substantial assets Finally Epstein is currently on work release running his financial affairs from his office giving him the clear opportunity to make the necessary arrangements to move his assets to overseas or other unreachable locations Thus there is a perfect circumstantial evidence case that Epstein has means motive and opportunity to fraudulently transfer assets See United states Sparks F.3d 9th Cir finding probable cause for an arrest based solely on a showing of means motive and opportunity The fact that this evidence is circumstantial rather than direct proof of the transfers is irrelevant because circumstantial evidence is not less probative than direct evidence and in some cases is even more reliable United States Ranum F.3d 7th Cir quoting United States Hatchett F.3d 7th Cir For all these reasons the Court should conclude that Epstein is fraudulently transferring assets Case Document Entered on FLSD Docket Page of CASE NO 08-CV--80119-MARRA/JOHNSON II JANE DOE IS ENTITELD TO THE PROTECTIONS OF THE UNIFORM FRAUDULENT TRANSFER ACT AS ADOPTED BY FLORIDA In light of Epsteins fraudulent asset transfers Jane Doe is entitled to pre judgment remedies to protect her against Epsteins efforts to block her from satisfying the judgment she is likely to ultimately obtain in this case Federal Rule of Civil Procedure guarantees Jane Doe during the course of this suit all remedies providing for seizure of person or property for the purpose of securing satisfaction of the judgment ultimately to be entered in the action that are available under the circumstances and in the manner provided by the law of the state in which the court is held The Rule goes on to provide that the remedies thus available include arrest attachment garnishment replevin sequestration and other corresponding or equivalent remedies however designated and regardless of whether by state procedure the remedy is ancillary to an action or must be obtained by an independent action This long-settled federal law provides that in all cases in federal court state law is incorporated to determine the availability of prejudgment remedies for the seizure of person or property to secure satisfaction of the judgment ultimately entered Rosen Cascade Intern Inc F.3d 11th Cir Accordingly under this Rule this Court looks to Florida law to determine Jane Does rights to pre judgment relief To prevent fraudulent transfers of assets before judgment Florida has adopted the Uniform Fraudulent Transfer Act Fla Stat Ann et seq Under the Floridas Uniform Transfer Act FUFTA courts are broadly empowered to take action to block certain fraudulent transfers of assets Jane Doe is accordingly entitled to invoke the remedies under this Act if Epstein is making fraudulent transfers of his assets Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON The Act defines a fraudulent transfer of assets as one made with actual intent to hinder delay or defraud any creditor of the debtor Fla Stat Ann a The FUFTA also contains a quite broad definition of transfer Nationsbank N.A Coastal Utilities Inc So.2d Fla Ct Apps It extends to every mode direct or indict absolute or conditional voluntary or involuntary of disposing of or parting with an asset or an interest in an asset and includes payment of money release lease and creation of a lien or other encumbrance Fla Stat Ann This broad definition includes every mode of disposing of an asset and does not limit the statute to direct transactions made by the debtor him/herself Nationsbank N.A Coastal Utilities Inc So.2d As noted above Epstein is transferring his assets with the intent to defeat any judgment that might be entered against him in this and other similar cases see Statement of Material Facts and therefore is plainly covered by the Act The FUFTA extends is protections to creditors such as Jane Doe who is a creditor of Epsteins within the meaning of the Act The FUFT A extends its protections not merely to judgment creditors but more widely to future creditors who have a claim including a claim that has not yet been reduced to judgment See Fla Stat Ann defining a claim as a right to payment whether or not the right is reduced to judgment liquidated unliquidated fixed contingent matured unmatured disputed undisputed legal equitable secured or unsecured Fla Stat Ann defining creditor protected by the act as a person who has a claim See generally Freeman First Union Nat Bank So.2d Fla noting that the definition of Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON claim is broadly constructed under the FUFTA This means that as is universally accepted as well as settled in Florida a claim under the Act may be maintained even though contingent and not yet reduced to judgment.H Freeman at internal quotations omitted In Florida then tort claimants are as fully protected against fraudulent transfers as holders of absolute claims Id at quoting Money Powell So.2d Fla Ct Apps Jane Doe is of course a tort claimant against Epstein For all these reasons Jane is entitled to the full protections of the Florida Uniform Fraudulent Transfer Act UNDER THE UNIFORM FRAUDULENT TRANSFER ACT JANE DOE IS ENTITLED TO THE REMEDIES OF APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF EPSTEINS Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON Jane Doe seeks one of these specifically provided remedies namely appointment of a receiver to take charge of Epsteins assets Appointment of a receiver will serve three important goals first if a receiver has control of Epsteins assets Epsteins ability to further transfer those assets will be blocked second the receiver can provide an accountlng of Epsteins assets allowing Jane Doe and the Court to take whatever other action may be appropriate and third the receiver can post a bond of million with the Court so that Jane Doe will have funds to satisfy any judgment that she might obtain The Court should appoint a receiver to account for Epsteins assets The appointment of a receiver is directly authorized by the FUFTA Fla Stat Ann 0B see Freeman First Union Nat Bank So.2d Fla noting that appointment of a receiver is remedy provided by the FUFT A A receiver is the only way to start to block further dissipation of assets by first gaining control over Epsteins assets and then second making an accounting of what assets of Epsteins remain in this country or are otherwise subject to control by this Court Given Epsteins Fifth Amendment invocations and other obstructions regarding any discovery concerning his assets see Statement of Material Facts it is currently impossible for Jane Doe to protect her interests in blocking Epsteins fraudulent transfers Indeed one of the other remedies specifically specified in the Act an injunction against further disposition by the debtor of the asset transferred is presumably unworkable given that there is no way to know what assets Epstein possesses much less where he is transferring them to Cf Special Purpose Accounts Receivable Co-op Corp Prime One Capital Co L.L.C WL S.D Fla Marra refusing to Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON apply any heightened pleading requirements to UFTA claims gJiven this lack of access to information on the part of a plaintiff in a fraudulent transfer case Jane Doe therefore needs a receiver to account for Epsteins assets to the Court The receiver should make a report to the Court regarding Epsteins assets so that Jane Doe can determine what additional further action is required For example Jane Doe might need to take action to set aside various transfers But even now it is clear that the receiver should take one additional step Once a receiver is appointed and accounts for Epsteins assets the receiver should post a million bond on behalf of Epstein with the Clerk of the Court in order to satisfy any judgment that Jane Doe might obtain in this case A million bond is reasonable First given Epsteins tremendous net worth he can post a million bond without any financial or other difficulty See Statement of Material Facts Second given the egregious acts of sexual abuse Epstein committed against Jane Doe who was a minor at the time and the punitive damages claim present in this case million is a reasonable bond amount given the nature of the judgment that Jane Doe is likely to obtain at trial Jane Doe seeks more than million damages See First Amended Complaint Her complaint alleges that Jeffrey Epstein had a sexual obsession for minor girls Id at To satisfy that obsession Epstein engaged in an elaborate scheme whereby his assistants recruited minor girls for the purpose of engaging in prostitution Id at Her complaint explains that Beginning in approximately February and continuing until approximately June the defendant coerced and enticed the impressionable vulnerable and economically deprived then minor Jane AM Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON der to commit various acts of sexual misconduct against her included but were not limited to fondling and inappropriate ti sexual touching of the then minor Jane Doe sexual and masturbation of Defendant Jeffrey Epstein in the of the then minor Plaintiff and encouraging and coercing the Plaintiff to become involved in prostitution Doe finally notes that in June Epstein entered pleas of guiltyn to tate crimes involving the solicitation of minors for prostitution and the 1inors for the purposes of prostitution for which Defendant Epstein was months incarceration in Palm Beach County jail to be followed by ity control house arrest Id at 1l has propounded various discovery requests regarding these effrey Epstein It is noteworthy that Epstein has asserted a Fifth incrimination privilege to these requests rather than provide answers ne Doe has asked Epstein to admit that he committed sexual assault when she was minor Plaintiffs First Request for Admissions to in In response Epstein asserted his Fifth Amendment privilege not nself ise reasons directing the receiver to post a million bond on behalf enable under the circumstances I also grants the court equity powers to remedy fraud lnvo omerset Venturer Inc So.2d Fla Ct Apps Visions are supplemented by the principles of law and equity.n Fla It is well-settled that an equitable action requires equitable Tyler So.2d Fla and equity will do what ought to I I Case Doe in These ac1 and illeg miscondw presence then mino Id at I Jane various Florida procurement of sentenced to months commun Jane allegations to Ji Amendment self For example Ja against Jane De Defendant Epste to incriminate hir For all the of Epstein is rea The UFT1 Florida Inc The FUFTAs pr Stat Ann relief Prince Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON be done Sterling Brevard County So.2d Fla Ct Apps The Court should therefore also exercise its equitable powers to impose the same remedies that Jane Doe requests Of course in equity the Court considers the relative positions of the two claimants Here Jane Doe has presented substantial claims of sexual abuse against her while a minor while Epstein who pied guilty to felony charges involving such conduct has taken the Fifth Amendment rather than answer questions about his sexual abuse of Jane Doe If Jane Doe does not obtain the remedy that she is requesting then Epstein may well be able to move all of his assets to unreachable locations leaving her with a substantial tort claim and no possible way to satisfy it On the other hand appointing a receiver will not interfere with any legitimate interest of Epstein particularly given his phenomenal wealth When this Court proceeds in equity it will not suffer a wrong to be without a remedy Connell Mittendorf So.2d Fla Ct Apps This case cries out for the Court to intercede and take action to avoid allowing a confessed and wealthy sex offender from concealing his assets and depriving his victims including Jane Doe from satisfying any judgment that they may well obtain against him A receiver with control over Epsteins assets is a modest and entirely appropriate step to take given Epsteins actions For the consideration of the Court a proposed order adopting these remedies is attached to this pleading Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON CONCLUSION WHEREFORE in view of the fraudulent transfers being made by Jeffrey Epstein to prevent Jane Doe from satisfying any judgment she might obtain in this case the Court should appoint a receiver to take charge of Epsteins property and direct the receiver to provide the Court with an accounting of Epsteins assets and post a million bond to secure any potential judgment that Jane Doe might obtain in this case DATED this th day of June Respectfully Submitted Bradley Edwards Bradley Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre East Las Olas Blvd Suite Fort Lauderdale Florida Telephone Facsimile Florida Bar No E-mail bedwards rra-law.com And Paul Cassell Pro Hae Vice Salt Lake City UT Telephone Facsimile E-Mail cassellp law.utah.edu AM Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON CERTIFICATE OF SERVICE CERTIFY that on June electronically filed the foregoing Clerk of the Court using CM/ECF I also certify that the foregoing served this day on all parties on the attached Service List in the either via transmission of Notices of Electronic Filing generated by ne other authorized manner for those parties who are not authorized to ally filed Notices of Electronic Filing Bradley Edwards Bradley Edwards Case I HEREB document with document is bei manner specifiec CM/ECF or in soi receive electronic ase Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON SERVICE LIST Jane Doe Jeffrey Epstein United States District Court Southern District of Florida Jack Alan Goldberger Esq Jgoldberger agwpa.com Robert Critton Esq rcritton bclclaw.com Isidro Manual Garcia isid rogarcia bellsouth.net Jack Patrick Hill iph searcylaw.com Katherine Warthen Ezell KEzell podhurst.com Michael James Pike MPike bclclaw.com Paul Cassell cassellp bclclaw.com Richard Horace Wlits lawyerswill its aol com Robert Josefsberg nosefsberg podhurst.com Adam Horowitz ahorowitz sexabuseattorney.com Stuart Mermelstein ssm sexabuseattorney.com William Berger wberger rra-law.com Document Entered on FLSD Docket Page of AFFIDAVIT OF PAUL CASSELL ESQUIRE I Paul Cassell have person lmowledge of the matters set forth herein I attorney licensed to practice in the State of Utah since My office is lat the University of Utah College of Law where I am a law professor with other attorneys I represent plaintiff Jane Doe in this matter It appears that defendant Jeffrey Epstein is an extremely wealthy lual According to reputable press reports his net worth is in the hundreds ions of dollars if not indeed a billion dollars See e.g New York Time at A2 Over the weekend Jeffrey Epstein who after years of 1g billionaires became a billionaire himself left his estate on Little St James with its staff of and its flamingo-stocked lagoon boarded a private ter and flew to Florida There he turned himself in at the Palm Beach jail and began serving months for soliciting prostitution According Wikipedia entry about Jeffrey Epstein he is a billionaire and owner of a island in the Virgin Island Little St James Island and was a financial at Bear Stearns He then founded his own financial management firm I I EXH Case aman locatec Along indivic of mill July I advisiI Islandl helico1 Coun to the privatt trader ocument Entered on FLSD Docket Page of alled Financial Trust Co located on his private island in He reportedly only took billionaire clients ys and I have made repeated efforts to find published 1dant Jeffrey Epstein in general and his financial dealings in tailed published source of information about defendant lve been able to locate is an article that was published in ard Vicky Ward is a contributing editor to Vanity Fair a nd a weekly columnist for the London Evening Standard i in the internet at 1ordpress archi ves/30 the Vanity Fair article defendant Jeffrey Epstein became 1e financial assets of other billionaires He reportedly se whose net worth was more than billion Unlike other Epstein kept all his deals and clients secret with one Leslie Wexner-who Epstein claims was his mentor He Lg in international currency markets which helped him and bis clients As a result it is reasonable to infer that he Case Epstein and Col later the U.S Virgin Island Other attome information about defer particular The most de Jeffrey Epstein that I h2 Vanity Fair by Vicky contributor to CNBC a The article can be fow1 http vickyward.com/v According to wealthy by managing tl limited his clients to the fund managers howeve exception billionaire has great skills in tradir make money for himse
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