Epstein Secrets

-polar disorder are more than simple allegations of emotional distress thus placing plaintiffs mental condition at issue). See also United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)( dealing with "admissibility of other acts of sexual abuse by individuals Case 9:08-cv-80119-KAM Document 362 E

0381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 I Defendant, Jeffrey Epstein's Reply to Plaintiff, Jane Doe 2-8, Response In Opposition To Defendant's Motions For Independent Examination Of Plaintiffs, With Incorporated Memorandnm Of Law Defendant, JEFFR

d on FLSD Docket 05/05/2009 Page 9 of 11 1998)(discoverability of Plaintiff's history of sexual activity is relevant to damages); United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)(deals with "admissibility of other acts of sexual abuse by individuals other than the defendant to explain why a vict

CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. I ------------- MOTION TO COMPEL AND/OR IDENTIFY JANE DOE IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY, OR ALTERNATIVELY, MOTION TO DISMISS

in her complaint, and whether she suffered injury and damages as a result of the other claimed sexual misconduct with males. See United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)(Defendant charged with sexual abuse of six year old boy was entitled to admission of evidence relating to victim's se

ANT'S REASONABLE EXPENSES Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, moves this Court for an order compelling Plaintiff, JANE DOE No. 2 to answer Defendant's First Set of Interrogatories and to overrule her objections asserted in Plaintiff's Answers To Defendant's First Interr

iated with those complex medical issues. Accordingly, the Motions for Protective Order should be denied and/or stricken. See also United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)(dealing with "admissibility of other acts of sexual abuse by individuals other than the defendant to explain why a vic

7/21/2009 Page 2 of 22 Page2 JANE DOE NO. 5, Plaintiff, JEFFREY EPSTEIN, Defendant. JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. JANE DOE NO. 7, Plaintiff, JEFFREY EPSTEIN Defendant. C.M.A., Plaintiff, JEFFREY EPSTEIN Defendant. CASE NO.: 08-CV-80381-MARRA/JOHNSON CASE NO.: 08-

at same right in the instant matters. 8 Case 9:08-cv-80119-KAM Document 104 Entered on FLSD Docket 05/19/2009 Page 9 of 13 Page9 States v. Bear Stops. 997 F.2d 451 (8th Cir. 1993); Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998). The information sought in

t. ---------~' JANE DOE NO. 7, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ---------~' C.M.A., Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. CASE NO.; 08-CV-80994-MARRA/JOHNSON CASE NO.; 08-CV-80993-MARRA/JOHNSON CASE NO.; 08-CV-8

CA 1997), rev. denied, 719 So.2d 286 (Fla. 1998)(discoverability of Plaintiffs history of sexual activity is relevant to damages); United States v. Bear Stops 997 F.2d 451 (8th Cir. 1993)(deals with "admissibility of other acts of sexual abuse by individuals other than the defendant to explain why a victi

ury and justice shall be administered without sale, denial or delay. Art. I, §21, Fla. Const.; 10A Fla. Jur. 2d, Constitutional Law, §360. 16. If Jane Doe's name is not disclosed and identified, Mr. Epstein will not be afforded his fundamental right to fairly litigate this dispute and prepare for trial.

lingly or not willingly engaged in sexual activity that has been photographed, or filmed by means of movie, dvd or videotapes. See United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)(Defendant charged with sexual abuse of six year old boy was entitled to admission of evidence relating to victim's se

ges that "Epstein committed willful acts of child sexual abuse" on her, which resulted in "mental or sexual injury," and "caused or likely to cause Jane Doe's mental or emotional health to be significantly impaired." 2d Am. Complaint, ¶25. The items sought are clearly relevant to the injuries and damages

d in her complaint, and whether she suffered injury and damages as a result of the other claimed sexual misconduct with males. See United States v. Bear Stops 997 F.2d 451 (8th Cir. 1993)(Defendant charged with sexual abuse of six year old boy was entitled to admission of evidence relating to victim's sex

eges that "Epstein committed willful acts of child sexual abuse" on her, which resulted in "mental or sexual injury," and "caused or likely to cause Jane Doe's mental or emotional health to be significantly impaired." 2d Am. Complaint, ¶25. The information sought is dearly relevant to the injuries and dama

ed on FLSD Docket 05/05/2009 Page 9 of 11 1998)(discoverability of Plaintiffs history of sexual activity is relevant to damages); United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)(deals with "admissibility of other acts of sexual abuse by individuals other than the defendant to explain why a vict

ury and justice shall be administered without sale, denial or delay. Art. I, §21, Fla. Const.; 10A Fla. Jur. 2d, Constitutional Law, §360. 15. If Jane Doe's name is not disclosed and identified, Mr. Epstein will not be afforded his fundamental right to fairly litigate this dispute and prepare for trial.

A 1997), rev. denied, 719 So.2d 286 (Fla. 1998)(discoverability of Plaintiff's history of sexual activity is relevant to damages); United States v. Bear Stops 997 F.2d 451 (81h Cir. 1993)(deals with "admissibility of other acts of sexual abuse by individuals other than the defendant to explain why a victi

ould ultimately result in reversible error at any trial. II. Conclusion and Prayer for Relief 22. Epstein requests the following relief: a. That JANE DOE's Motion to Proceed Anonymously be denied; b. That this Court grant Epstein's Motion and that JANE DOE be identified by her legal name in the style