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This is a Memorandum of Law filed by the defendants (Executors of the Estate of Jeffrey Epstein) in support of their motion to dismiss the plaintiff's complaint. The defendants argue that the plaintiff's claims of sexual assault and battery are time-barred by the applicable statutes of limitations in multiple jurisdictions (USVI, NY, NM, FL, France) and that exceptions like CPLR 215(8)(a) or equitable tolling do not apply. Additionally, the defendants argue that punitive damages are not recoverable against a deceased tortfeasor's estate under the laws of any relevant jurisdiction.
This document is a chain of emails from September 2021 forwarding archived communications from October 2019 regarding the Epstein/Maxwell discovery process. The 2019 emails detail travel arrangements for a victim to fly to New York for a meeting at the FBI New York Field Office, including hotel accommodations at the Moxy NYC Downtown and reimbursement policies for ground transport. The correspondence highlights the FBI's coordination with a victim witness during the investigation.
An email thread from July 2019 forwarded to Ben Nivens containing a response to a 'Hope for Justice' preliminary questionnaire regarding human trafficking. The respondent claims to have been born into sex trafficking by their biological parents and specifically names Jeffery Epstein as a perpetrator who used threats of death and harm to force them into sex acts. The narrative mentions incidents occurring in a specific (redacted) year when the victim was a (redacted) age.
This document is an Institution Supplement (NYM - 6031.03C) for the Metropolitan Correctional Center (MCC) in New York, dated May 29, 2013. It establishes detailed policies and procedures for inmate patient care, including intake screening, sick calls, urgent medical/dental/psychiatric services, and emergency response protocols. It specifically notes that due to the high-rise nature of the facility, emergency medical vehicles are not appropriate on-site, and designates New York Down Town Hospital for life-threatening emergencies and Brooklyn Hospital for urgent but non-life-threatening cases.
This document is an internal email from an Assistant US Attorney (SDNY) dated September 28, 2021, discussing potential trial exhibits (ESI). The email reveals that evidence was recovered from a computer registered to 'gmax' (likely Ghislaine Maxwell), which was a clone of a computer from Epstein's Palm Beach house created by his private investigators in 2005. The FBI recovered these cloned drives from Epstein's NYC townhouse in 2019.
This document is an AT&T Wireless invoice for Jeffrey E. Epstein for the billing period ending May 02, 2004. It details extensive call logs including domestic calls primarily between New York and Florida, as well as international activity involving France, the UK, Brazil, and Belgium. The invoice specifically documents a trip to St. Thomas, US Virgin Islands (CHTAMSTTHS VI), between April 6 and April 8, 2004, evidenced by 'Roamer Usage' logs.
This document contains a response from T-Mobile USA to an FBI subpoena dated March 23, 2007, providing subscriber information and call detail records for Jeffrey E. Epstein. The records cover a period from February 2005 to February 2006 and show extensive usage including calls to/from New York, Florida, Ohio, the U.S. Virgin Islands (Charlotte Amalie), and the British Virgin Islands, as well as international communications to Lithuania and Poland. A second subpoena response for a different, redacted account in Brooklyn, NY indicates 'No CALLS' were found for that number.
This document is a detailed itemized phone bill from T-Mobile covering the period of October 31, 2006, to December 31, 2006. It lists thousands of voice calls, primarily originating from or connecting to locations in the New York area, specifically White Plains, The Bronx, and Manhattan. While the specific phone numbers called are redacted, the bill shows high-frequency communication, including calls to Directory Assistance (411), Customer Care, and a few out-of-state calls to Norfolk, VA, Bordentown, NJ, and Montgomery, TX. This is strictly a telecommunications record and contains no flight logs or aircraft data.
This document is a list of professional activities and engagements, likely for an academic or legal professional, spanning from 1998 to 2000. It details various conferences, lectures, meetings, and academic affiliations across numerous universities, legal associations, and scientific organizations in the United States and internationally. The topics covered include memory, psychology, law, criminal defense, and wrongful convictions.
This document is page 81 of a court transcript from the Jeffrey Epstein case (1:19-cr-00490) filed on September 3, 2019. It contains a harrowing victim impact statement describing forceful sexual penetration, psychological manipulation, threats of ruin ("I'll bury you"), and the routine nature of paid sexual encounters at Epstein's mansion. The victim describes the involvement of assistants who managed the schedule and witnessed Epstein bragging about the abuse.
This document is a transcript of a sidebar conference during the trial of Ghislaine Maxwell. The defense (Mr. Everdell) argues against admitting evidence regarding the death of Maxwell's father and her subsequent move to a smaller apartment, claiming it predates the alleged conspiracy by three years. The prosecution (Ms. Comey) argues this evidence is relevant to establish motive, specifically that Maxwell was not wealthy and participated in crimes with Jeffrey Epstein in exchange for financial support, including the purchase of a large townhouse.
This document is a court transcript of testimony from a witness named Farmer. She recounts a weekend during which Jeffrey Epstein and Ghislaine Maxwell took her on a shopping trip into town from their ranch. During the trip, Ghislaine bought her a hair product, and Epstein purchased a pair of cowboy boots for her, with Maxwell also present.
This document is a printout of a MySpace profile page for user 'sublimehottie' (associated with Virginia Roberts Giuffre), containing comments from friends between February 2nd and February 8th, 2006. The page lists movie interests and includes messages regarding social visits to 'o town' (Orlando), a random encounter at a house, and a planned visit from a friend named Nick. The document originates from a Department of Justice Public Records Request (17-295) produced in 2017.
This document is a page from the court transcript of the direct examination of a witness named Visoski. Visoski testifies about working for Ms. Maxwell in the 2000s, describing visits to her Manhattan brownstone to handle luggage, sign expense reports, and install a home theater on the sixth floor. The witness also provides a layout description of the brownstone's lower levels.
This document contains photocopies of blank banking stationery belonging to Janusz and Beata Banasiak. It includes a transaction register cover, a blank check, and a blank deposit ticket for an account at BB&T in Charlottesville, Virginia. The account holders' address is listed in Germantown, Maryland. The document dates '04/95' and '1/2001' appear as printing or account codes.
A printout of a MySpace comments page (Page 8 of 13) dated from February 2005. It features comments from users 'JGreen' (promoting a hardcore/metal concert at Spankys Downtown) and 'Virginia' (wishing the profile owner a Happy Valentine's Day), as well as a timestamped entry from user 'Dusty Wusty ♥s Candy'. The document bears Department of Justice Bates stamping DOJ-OGR-00032819.
This document is page 'vii' (Author's Note) from a book, produced as evidence in a House Oversight investigation. It details an anecdote where Tim Malloy observes a silver-haired man (fitting the description of Jeffrey Epstein) walking on Madison Avenue in monogrammed slippers accompanied by two young women acting as staff, before entering a 'fortress' town house on 71st Street.
The document contains pages from the book 'Filthy Rich' (page 285), stamped as evidence by the House Oversight Committee. It details the fallout for Jean-Luc Brunel, who sued his former friend Jeffrey Epstein for emotional distress and loss of business for his modeling agency, MC2, due to the association with Epstein's crimes. The text explicitly quotes Brunel acknowledging the extreme nature of Epstein's sexual abuse of minors while denying his own involvement. It also briefly mentions personnel changes within the Palm Beach Police Department, including a Detective 'Joe' receiving honors at Mar-a-Lago.
This document is page A40 of 46 from a Public Financial Disclosure Report (OGE Form 278e) filed by Donald J. Trump. It details the ownership structure of various entities including golf clubs, real estate holdings (1290 Avenue of the Americas), and operational LLCs, listing DJT Holdings LLC, The Donald J. Trump Revocable Trust, and 'Trump Family Members' as primary owners. The document bears a 'HOUSE_OVERSIGHT' stamp, indicating it was part of a production to the House Oversight Committee; there is no mention of Jeffrey Epstein or associated entities on this specific page.
This document is a section from a report (likely House Oversight) discussing Chinese influence operations at the state and local government level. It details a specific case study from 2017-2018 where a mid-Atlantic US city formed a sister city partnership with a Chinese town, highlighting how pro-CCP language was inserted into the agreement despite warnings from experts about Beijing's influence tactics. **Note:** While requested as an 'Epstein-related' document, the text strictly concerns US-China relations and local government influence, with no mention of Jeffrey Epstein.
This document is a court filing exhibit containing a 2003 Vanity Fair article excerpt detailing the relationship between Jeffrey Epstein and retail mogul Leslie Wexner. It describes how Wexner entrusted Epstein with full fiduciary power over his trusts and purchased the Manhattan town house where Epstein resided. The text highlights Epstein's aggressive business tactics, including conflicts with Wexner's family and threats to reporters, contrasted with anecdotes of his generosity toward friends' children.
This document appears to be a biographical profile or press sheet for Quincy Jones, dated roughly to 2008. It details his career achievements (autobiographies, Grammys), upcoming musical projects (Soul Bossa Nostra), and extensive philanthropic work, including 'We Are the World', Jubilee 2000, and the 'Project Q' partnership with the Harvard School of Public Health. The document is stamped 'HOUSE_OVERSIGHT_017545', indicating it is evidence within a House Oversight Committee investigation, likely related to files involving Jeffrey Epstein, though Epstein is not explicitly named in the text of this specific page.
This document appears to be a page from a draft manuscript or memoir, likely by Alan Dershowitz (evidenced by references to his books *The Case For Peace* and *The Case For Israel*). The text details the author's experience with anti-Israel protests, specifically an incident at Faneuil Hall where police escorted him away for safety, and compares current anti-Israel sentiment to historical hatreds like Nazism and Apartheid. It concludes by quoting an article by Kassim Hafeez about overcoming antisemitic upbringing.
This document appears to be a page from a book manuscript or legal commentary (dated April 2, 2012), likely written by Alan Dershowitz given the context of Harvard Law and debating Scalia. It critiques the US legal system's handling of 'actual innocence' claims, specifically highlighting the Jeffrey MacDonald case and the Supreme Court's stance. The text includes a 2009 challenge from the author to Justice Antonin Scalia regarding the compatibility of his constitutional views on execution with Catholic doctrine.
This document appears to be page 55 of a manuscript or memoir draft by Alan Dershowitz, dated April 2, 2012. It recounts his experiences as a law clerk in 1962-1963, specifically detailing a case involving a fraudulent lawyer named Morgan and Dershowitz's admiration for the appellate attorney Monroe Freedman. The text highlights a lesson Dershowitz learned from Judge Bazelon regarding the necessity of a solid legal basis for reversing convictions, ending with a parenthetical reference to Bush v. Gore.
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