Epstein Secrets

iption Publication, 8.41M) provides similar coverage. Gunman's Family Apologizes For His Actions. On ABC World News Tonight (4/17, story 2, 2:17, Johnson, 3.89M), Will Carr reported the gunman's family on Saturday "released a statement. They say they're devastated and they tried to get him help. They'

M), Kathy Park reported four of the victims "are still hospitalized. Everyone is in stable condition and are expected to survive." USA Today (4/18, Herron, Bacon, 12.7M) reports those who lost their lives "were identified as Amarjeet Johal, 66; Jasvinder Kaur, 50; Amarjit Sekhon, 48; Jaswinder Singh, 6

cument 81 Entered on FLSD Docket 04)20:2009 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80I I 9-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. REPLY MEMORANDUM IN SUPPORT OF MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PROD

amendment grounds each and every question, such repeated assertions are fairly characterized as a "blanket assertion". Id.; Capitol Products Corp. Herron, 457 F.2d 541 (8th Cir. 1972). Accordingly, it is not sufficient to support the invocation of the Fifth Amendment with nothing more than sweeping

ered on FLSD Docket 05/06/2009 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant.

to prevent a sexual battery and harassment victim from having to disclose off-duty sexual contacts with persons other than defendant in discovery); Herron,. Eastern Industries. Inc. 2007 WL 2781211 (N.D. Fla. Sept. 19, 2007); Gibbons'. Food Lion Inc. 1999 WL 33226474 (M.D. Fla. Feb. 19, 1999); P.J. He

red on FLSD Docket 05,06/2009 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant.

to prevent a sexual battery and harassment victim from having to disclose off-duty sexual contacts with persons other than defendant in discovery); Herron Eastern 4 EFTA00222174 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 5 of 10 Industries. Inc. 2007 WL 2781211 (N

iption Publication, 8.41M) provides similar coverage. Gunman's Family Apologizes For His Actions. On ABC World News TonightVi (4/17, story 2, 2:17, Johnson, 3.89M), Will Carr reported the gunman's family on Saturday "released a statement. They say they're devastated and they tried to get him help. They'

M), Kathy Park reported four of the victims "are still hospitalized. Everyone is in stable condition and are expected to survive." USA Today (4/18, Herron, Bacon, 12.7M) reports those who lost their lives "were identified as Amarjeet Johal, 66; Jasvinder Kaur, 50; Amarjit Sekhon, 48; Jaswinder EFTA001

cription Publication, 8.41M) provides similar coverage. Gunman's Family Apologizes For His Actions. On ABC World News Tonight (4/17, story 2, 2:17, Johnson, 3.89M), Will Carr reported the gunman's family on Saturday "released a statement. They say they're devastated and they tried to get him help. They

41M), Kathy Park reported four of the victims "are still hospitalized. Everyone is in stable condition and are expected to survive: USA Todav (4/18, Herron, Bacon, 12.7M) reports those who lost their lives "were identified as Amarjeet Johal, 66; Jasvinder Kaur, 50; Amarjit Sekhon, 48; Jaswinder Singh, 6