Epstein Secrets

ress," such claims are subject to the constitutional limitations and guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996)• Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Ligget Group, Inc., 945 So.2d 1246 (Fla. 2006). The

. Defendants in civil actions. - EXHIBIT A_ EFTA00221878 Case 9:08-cv-80119-KAM Document 148-2 Entered on FLSD Docket 06/09/2009 Page 2 of 10 Jane Doe No. 2 v. Epstein Page 2 '... a civil defendant who raises an affirmative defense is not precluded from asserting the privilege [against self-incri

ne 500 Companies and Selected Private and Government Organizations," Newport Beach, CA, April 24-26, 1995 Boise Cascade, Boise, ID, May 2-5, 1995 Philip Morris, Tucker's Town, Bermuda, May 10, 1995 First Data, Denver, CO, June 8-9, 1995 Corning, Inc., Corning, NY, June 14-15, 1995 GE Capital, Stamford, CT

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

ress," such claims are subject to the constitutional limitations and guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996)• Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007)• State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Ligget Group, Inc., 945 So.2d 1246 (Fla. 2006). The

d on FLSD Docket 06/08/2009 Page 5 of 11 CASE NO: 08-CV-80119-MARRA/JOHNSON Background Defendant Epstein has filed a boilerplate motion to strike Jane Doe's trial date — and numerous other consolidated cases involving similar allegations of his sexual abuse of minors - for an unspecified period of time,