Epstein Secrets

against the defendants in the Jane Doe Matter that she, herself, initiated prior to her appearance and production of that evidence in the Matter. Fourth, Jane Doe does not object to a modification of the Protective Order; she only takes issue with the scope of the proposed modification. Indeed, Jane

ce in its entirety is probative of the issues which will be raised in the Motion to Dismiss, including whether the statute of limitations has run on Jane Doe's claim, whether the Court in the Jane Doe Matter has personal jurisdiction over the defendants, and whether the Motion to Dismiss should be granted

mma to 23 chore so I'm understanding. no questionnaire that 24 stipulations. 24 you're proposing would be after the initial issues 25 And the Fourth has reiterated that in a recent 25 regarding knowledge of any of the participants in Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793861

RE II Deoksbor 5th and nide it clear to all parties that 10 12 exhibits that. here net disclosed by the end of II For Non-Parties L.M., E.M. 4 Jana Doe 22 1a Deoabor -- and I think it nay have been the 14 De her 22 dace -- I'm not sure about that exact 13 la date -- but exhibits that were no

mma to 23 chore so I'm understanding. no questionnaire that 24 stipulations. 24 you're proposing would be after the initial issues 25 And the Fourth has reiterated that in a recent 25 regarding knowledge of any of the participants in Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793814

question in front of you sight now is • very brief, representing three victims; LH, EM and • what to do about this. Well, we knee one thing. • Jane Doe. /Vat ono housekeeping natter. s lie know there's been absolutely no waiver of 10 No have riled a notion to intervene, which is 10 attorney/cl

ough counsel based upon the uncontroverted procedural history provided by Mr. Burlington in front of the Fourth District Court of Appeal that the Fourth decided, through Judge Warner's opinion, to address the Tipsy Coachman issue, address it they did, and they did not disturb the trial court's find

?" Refusal to answer. Fifth Amendment. At page 73, "I would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that federal complaint." Refusal to answer. Page 24. "Did you ever have any physical contact with Fifth Amendment. Refusal to answer. Page 26

hird and Fourth Districts have applied the litigation privilege to abuse of process claims. However, Wolfe itself, and the decisions of the Third and Fourth Districts cited in Wolfe, involved the litigation privilege as applied to claims of abuse of process by attorneys. None of the cases involved the ext

ards filed a civil sot against Jeffrey Epstein to recover damages for his sexual assault of L.M. See Complaint, LM. v. Epstein, (Exhibit “V”). 3 47. Jane Doe’s federal complaint indicated that she sought damages of more than $50,000,000. Listing the amount of damages sought in the complaint was in accord wit