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it would cause delay in one of the cases or if one of the cases is further into discovery than the other case”); see also Ford Motor Credit Co. v. Chiorazzo, 529 F.Supp. 2d 535, 542 (D.N.J. 2008) (denying consolidation of two actions because discovery was nearly complete in one while the other was in it
F FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPS
were not identical); Borough of Olyphant v. PPL Corporation et al., 153 Fed.Appx. 80, 2005 WL 2673489 (C.A.3 (P.A.)); Ford Motor Credit Company v. Chiorazzo, 529 F.Supp.2d 535 (D. N.J. 2008). Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery is not mandatory but
to one or more matters, one "witness" deposition will be held as to her witness knowledge. However, Defendant is also permitted to separately take Jane Doe. No. 3's deposition as a party-plaintiff. WHEREFORE, Defendant requests that this Court deny the Motion, enter an order allowing for the relief requ
were not identical); $orouah of Olvoliant v. PPL Corporation et al. 153 Fed.Appx. 80, 2005 WL 2673489 (C.A.3 (P.A.)); Ford Motor Credit Cornrow v. Chiorazzo, 529 F.Supp.2d 535 (D. N.J. 2008). Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery is not mandatory but
the federal rules while at the same time asking this court to limit or prevent her deposition testimony as a witness in the instant matter or other Jane Doe matters where she has been identified as a witness. It is well settled that a Defendant may take the deposition of a party and/or a witness before
Entities connected to both Chiorazzo and Jane Doe

Jeffrey Epstein
PERSONJack Goldberger
PERSONRobert D. Critton
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSONStuart S. Mermelstein
PERSONMermelstein & Horowitz
ORGANIZATIONClerk of the Court
ORGANIZATIONGeneral Motors Corp.
ORGANIZATIONFord Motor Credit Company
ORGANIZATION