Epstein Secrets

Document 60 Entered on FLSD Docket 04/17/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-NIARRA/JOHNSON C.M. A., Plaintiff, v. i EPSTEIN and Defendants, DEFENDANT's MOTION FOR EXTENSION OF TIME IN WHICH TO FILE A REPLY TO PLAINTIFF'S RESPONSE TO

settled that a Defendant may take the deposition of a ma and/or a witty-cc before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and lave v. General Motors Corp., 43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2-7 commenced separate civil actions upon the filing of same against Jeffrey Epstein. Therefore, Def

plaintiffs from attempting to depose other paralegals, secretaries, legal assistants, investigators or even attorneys employed by Epstein? As Judge Johnson noted, "while the scope of discovery is broad, it is not without limits." See DE #377. Jane Doe is clearly attempting to exceed the limits of permi

ts or representatives of a party's attorney. 12. The attorney-client privilege also extends to subordinates of a party's attorney. See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, et al. Defendant. Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-8046

er home (or, if necessary, other place of safety) without facing the threat of any further harassment or intimidation. See Serra Chevrolet, Inc. v. General Motors Corp., 446 F.3d 1137, 1147 (11th Cir. 2006) ("Civil contempt may be imposed in an ordinary civil proceeding upon notice and an opportunity to be heard.")

dence. Andrew Jackson helped to shaped the party and was a hero in his time. Truman used atomic bombs on Japan, killing 120,000 innocent people. Johnson escalated the war in Vietnam that ended up costing 58000 American live& He was a one-term president. Even Barack Obama said that he wanted a re

ere 34 percent lower than a year ago. "Stimulating sales is the only way to get the auto industry back on its led," said Rep. Donald Manzullo, General Motors Corp. and Chrysler LLC have received billions of dol- lars in government aid and the entire auto indus- try has watched car sales plummet during the pa

e generally constitutes an accounting method, and a change from one such practice to another generally constitutes a change in accounting method. In Johnson v. Commissioner, 108 T.C. 448 (1997), for example, the Tax Court held that switching the time for recognizing escrowed customer payments as gross i

). An accounting practice that involves the timing of when an item is included in income or when it is deducted is considered an accounting method. General Motors Corp. v. Commissioner, 112 T.C. 270, 296 (1999), Color Arts, Inc. v. Commissioner, T.C. Memo. 2003-95. An "item" is any recurring element of income or ex