Epstein Secrets

nagement, 201 F.R.D. 272 (D.D.C. 2001); See also, Salter v. Upjohn Co., 593 F.2d 649, 651 (5th Circ. 1979

x [email protected] Co-counsel/or Plaintiff Jane Doe Isidro M. Qarcia, Esq. Garcia Law Firm, P.A. 2

d supporting Zinoview's Motion for Protective Order. The court found that an order completely prohibiting the deposition from going forward is rare, Salter v. Upiohn co., 593 F.2d 649, 651 (5th Cir. 1979), and that Zinoview's conclusory affidavit in which he denies knowledge of the facts giving rise to

fected them emotionally and psychologically. See ~-, Exhibit "D", Affidavit of Richard C.W. Hall, outlining the psychological issues experienced by Jane Doe 4 as a result of incidents in her life prior to Epstein, which cannot be discounted. As such, Plaintiffs should not, once again, be able to "handpic

Cir. 1989). An order completely prohibiting a deposition from going forward, however, is rare, and only resorted to in extraordinary circumstances. Salter v. Upjohn Co., 593 F.2d 649, 651 (5 Cir. 1979)(noting that it is very unusual for trial court to th prohibit the taking of a deposition altogether,

T OF FLORIDA CASE NO: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN,

her back atis y- fabulous world that he Brooklyn boy knew not taught Epstein the differ But despite—or was il Epstein, she, too, gradi According to Jane Doe : | filed in 2009 by a womart Ly of the services Maxwell ment of underage wom papers, Maxwell has ve Virginia, with any othe with, or with any crim

oke, with the benefit of hindsight, about Jeffrey 4 Epstein and others like him from her office in Madison, Wisconsin. | _ “Consider a car,” says Dr. Salter. “There’s a motor, and there "are brakes. We all have sexual impulses we don’t think it would bea good idea to act on. Most of us have good control o

e spoke, with the benefit of hindsight, about Jeffrey _ Epstein and others like him from her office in Madison, Wisconsin. “Consider a car,” says Dr. Salter. “There’s a motor, and there "are brakes. We all have sexual impulses we don’t think it would be a good idea to act on. Most of us have good control

rt in the lawsuit. : But then, the allegations m Jane Doe 3 is Virginia Roberts, the girl who says that Ghi