Epstein Secrets

EFFREY EPSTEIN, Defendant. MOTION TO COMPEL PROPER RESPONSES TO PLAINTIFF'S SUPPLEMENTAL REQUESTS FOR ADMISSION DATED FEBRUARY 4, 2010 Plaintiff, B.B., by and through undersigned counsel, hereby files this Motion to Compel Defendant, JEFFREY EPSTEIN, to properly respond to Plaintiff's Requests for

n Dated February 4, 2010, and as grounds therefore states as follows: 1. On February 4, 2010, Plaintiff served Defendant with twelve Requests for Admissions. (Exhibit "A"). 2. On March 17, 2010, Defendant responded to each Request identically (Exhibit "A") — in essence acknowledging that Defendant inte

EFFREY EPSTEIN, Defendant. MOTION TO COMPEL PROPER RESPONSES TO PLAINTIFF'S SUPPLEMENTAL REQUESTS FOR ADMISSION DATED FEBRUARY 4, 2010 Plaintiff, B.B., by and through undersigned counsel, hereby files this Motion to Compel Defendant, JEFFREY EPSTEIN, to properly respond to Plaintiff's Requests for

n Dated February 4, 2010, and as grounds therefore states as follows: 1. On February 4, 2010, Plaintiff served Defendant with twelve Requests for Admissions. (Exhibit "A"). 2. On March 17, 2010, Defendant responded to each Request identically (Exhibit "A") — in essence acknowledging that Defendant inte

Conference with JMB - list of to do re: Joe G; telephone conference with JE 0.70 hr $350.00 03/30/2009 RDC Objection to Yellow Cab and letter (B.B.) 0.40 hr $200.00 03/30/2009 RDC Telephone call from Jack re: A.0 and notes 0.20 hr $100.00 03/30/2009 RDC Motion to Quash in BB 0.60 hr $

E 0.50 hr $250.00 03/26/2009 RDC Receipt and review Doe (Fed) First Interrogatories; First Request to Produce; 1st 0.30hr $150.00 Request for Admissions 03/26/2009 RHB Conference with RDC. EW, and LM regarding Motions to Dismiss; SR/JD no private c/a 0.20 hr $60.00 03/26/2009 RHB Legal resear

e materials. The Government has already followed this procedure elsewhere and should do so here. See, e.g., Bates 000966-67 (materials about victim "B.B."). No Assertion of Privacy Rights by Other Victims. Several of the victims cited by the Government are represented by undersigned counsel and do no

ss. However, I did not have any direct way of contradicting Reinhart's sworn statement. Since then, however, in answering the victims' Requests for Admissions, the Government has admitted that it possesses information that Reinhart learned confidential, non-public information about the Epstein case and th