Epstein Secrets

edule in this case, 2 EFTA00722412 Case 9:10-cv-81111-WPD Document 15 Entered on FLSD Docket 11/11/2010 Page 3 of 16 CASE NO: 08-CV-80119-NIARRA/JOHNSON and to Order Epstein to immediately file an Answer to MJ's Complaint or alternatively to Strike Epstein's pleadings. FACTUAL BACKGROUND At any he

e court must then "weigh and determine (the) disputed issues of facts on a Rule 12(b)(5) motion." Cranford v. United States, 359 F.Supp.2d 981, 984 (E.D. Cal. 2005). An evidentiary hearing is the proper vehicle for resolving this particular factual dispute. See Blair v. City of Worcester, 522 F.3d 105, 1

Document 57 Entered on FLSD Docket 03;022009 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION OF DOCUMENTS

purely procedural in nature and does not create a federal physician-patient or hospital-patient privilege." Allen v. Woodford 2007 WL 309485 *I I (E.D. Cal. 2007). Under HIPAA, health care information may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing

application of §2255 for appeal. See C.MA. v. Epstein, Case No. 08-CIV-80811 Marra/Johnson; and Jane Doe II v. Epstein, Case No. 09-CW-80489 Marra/Johnson. EFTA00207698 Case 9:08-cv-80893-KAM Document 128 Entered on FLSD Docket 03 05 2010 Page 23 of 36 Jane Doe v. Epstein Case No. 08-CV-80893-Marra

CV-80893-Marra-Johnson Page 7 Cal. Aug. 19, 2009); U.S. v. Ferenci, 2009 WL 2579102, fn. 1 (ED. Cal. Aug. 19, 2009); U.S. 2009 WL 2567831, fn. 1 (E.D. Cal. Aug. 18, 2009); U.S. v. Zane, 2009 WL 2567832, al (ED. Cal. Aug. 18 2009). In each of these cases, the referenced footnote states — Prior to July

Document 57 Entered on FLSD Docket 03;022009 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION OF DOCUMENTS

purely procedural in nature and does not create a federal physician-patient or hospital-patient privilege." Allen v. Woodford 2007 WL 309485 *I I (E.D. Cal. 2007). Under HIPAA, health care information may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing

wed up. Police found child porn on his computer and condoms in his car. 241/4r2;); 2423(b) Not Consummated. Showed up at meeting Sting U.S. I Johnson. 221 F.3d 83 (2°‘ Cir. 2000) Internet Internet contact with 3 separate minor girls and traveled to engage in illegal sexual conduct; traveled fr

conduct evidentiary hearing. 2422(b); 2423 Not Consummated Showed up for meeting Sting E.D. Cal. U.S. I Carter, 2006 U.S. Dist. LEXIS 22501 (E.D. Cal. 2006) Internet Internet chat room "preteen parents who share"; defendant wants to have sex with daughter while mother watches; Internet email &

0 1004 D.C. ELECT RODIC UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: Dg C V gocq3 rAyniz_Rs JANE DOE, 08-80893-Civ-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. AUGUST 13, 2008 STEVEN M. LARIMORE CLERK U.S. GIST. CT. S.D. OF FLA. • MIAMI FILED by O.C. AUG

ases, with minimal discussion. Roe v. Wade, 410 U.S. 113, 120-121, 93 S.Ct. 705 (1973); See also, E.E.O.C. v. ABM Industries, Inc., 249 F.R.D. 588 (E.D. Cal. 2008). Likewise, pseudonym filing is typically accepted by the courts in other cases where the nature of the pleading unveils highly sensitive inf

eepers Gang members; pimp recruited underage girls for prostitution and traveled interstate with them. 2422(b); 2423(b) No Information U.S. v. Johnson, 221 F.3d 83 (2"d Cir. 2000) Internet Internet contact with 3 separate minor girls and traveled to engage in illegal . sexual conduct. Pled gui

uct evidentiary hearing. 2422(b); 2423 Not Consummated Showed up for meeting Sting G.D. Cal. • U.S. v. Carter, 2006 U.S. Dist. LEXIS 22501 (E.D. Cal. 2006) . Internet Internet chat room "preteen parents who share"; defendant wants to have sex with daughter while mother watches; Internet emai

eepers Gang members; pimp recruited underage girls for prostitution and traveled interstate with them. 2422(6); 2423(b) No Information U.S. v. Johnson. 221 F.3d 83 (2nO Cir. 2000) Internet Internet contact with 3 separate minor girls and traveled to engage in illegal sexual conduct. Pled guilt

onduct evidentiary hearing. 2422(b); 2423 Not Consummated Showed up for meeting Sting E.D. Cal. U.S. v. Carter, 2006 U.S. Dist. LEXIS 22501 (E.D. Cal. 2006) Internet Internet chat room "preteen parents who share"; defendant wants to have sex with daughter while mother watches; Internet email &

et; arranged to meet her for sex; met her and had sex. Pled guilty. Motion to withdraw guilty plea denied. 2422(b) Consummated D. Nev. U.S. I Johnson, 445 F. Supp. 2d 1181 (D. Nev. 2006) Internet Internet communications; arranged to meet for sex and meet for sex; state charges dropped but fed

conduct evidentiary hearing. 2422(b); 2423 Not Consummated Showed up for meeting Sting E.D. Cal. U.S. I Carter, 2006 U.S. Dist. LEXIS 22501 (E.D. Cal. 2006) Internet Internet chat room "preteen parents who share"; defendant wants to have sex with daughter while mother watches; Internet email &