Epstein Secrets

AN A FAIRBANKS,DANIEL J HAMILTON JR,S. MATTHEWS SCAIFE,JENNIE K ECHAVARRIA,LOUISE

QUINN,OLIVER H LOCKER,NANCY OWEN,JANE D CUSHMAN & WAKEFIELD KELLER,MICHAEL

v. Scalese, 799 So. 2d 382, 384 (Fla. 4th DCA 2001) (issues regarding the intent of the parties could not be decided on summary judgment). See also Matthews v. Storgion, 335 F. Supp. 2d 878, 886 (W.D. Tenn. 2004) (genuine issue of material 25 EFTA00808050 Epstein v. Rothstein and Edwards Case No. 502

perfield and Bill Richardson for deposition en 70-75); purported relevancy of pilot and flight logs to show interstate airplane travel in support of Jane Doe's Federal Rico claims and punitive damages (911 77-79); Epstein's interview with a New York newspaper reporter (9191 80-81); Epstein's alleged threat

e (Phoenix, Arizona) Testified at trial, 12/18/96 Commonwealth of PA v. John duPont (Media, Pennsylvania) Testified at trial, 2/12/97 and 2/13/97 Matthews v. Roman Catholic Bishop of Portland (Portland, Maine) Testified at deposition, 3/11/97 People of CA v. Joshua Jenkins (Vista, California) Testifi

k, New York) [2nd Circuit Opinion: 938 F.2d 1535 (2nd Cir. 1991)] Testified at deposition, 5/13/90 Testified in court (trial or hearing), 5/14/90 Jane Doe v. Stuart Brown. M.D. (San Diego, California) Testified by deposition, 6/6/90 Carin Evans vs. Richard Benton, Ph.D. (Houston, Texas) Testified at

volves the narrow issue of whether Defendant defamed two lawyers. Defendant’s subpoena is both unreasonable and oppressive and should be quashed. See Matthews v. Kant, 427 So. 2d 369, 370 (Fla. 2d DCA 1983). 2. The Court Should Quash The Subpoena In Its Entirety, But At A Minimum, It Should Severely Limit

lations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein’s and well-known criminal defense attorney. Epstein required Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, N