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are all witnesses and parties 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 m
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
share all witnesses and parties were not identical); Borough of Olvphant v. PPL Comoration et al., 153 Fed.Appx. 80, 2005 WL 2673489 (CA.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 ma
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
hare all witnesses and parties 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 ma
v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE ORDER AND TO_QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO.3, MOTION TO CONSOLIDATE CASES FOR PURPOSES OF DISCOVERY, AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT Defendant, JEFFREY EPSTEIN, by and thro
hare all witnesses and parties 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 ma
v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE ORDER AND TO_QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO.3, MOTION TO CONSOLIDATE CASES FOR PURPOSES OF DISCOVERY, AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT Defendant, JEFFREY EPSTEIN, by and thro
are all witnesses and parties were not identical); Borouzh of Olvphant 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 m
v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO.3, MOTION TO CONSOLIDATE CASES FOR PURPOSES OF DISCOVERY. AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT Defendant, JEFFREY EPSTEIN, by and thro
Entities connected to both Ford Motor Credit Company and Jane Doe

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONRobert D. Critton
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSONStuart S. Mermelstein
PERSONMermelstein & Horowitz
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATIONLuttier & Coleman
ORGANIZATIOND. Critton
PERSONFlorida Rules of Civil
ORGANIZATIONGeneral Motors Corp.
ORGANIZATIONF.R.D. 508
ORGANIZATIONKelly v. Kelly
PERSONLeve v. General Motors Corp.
ORGANIZATIONN.D. NY
ORGANIZATIONOlyphant v. PPL Corporation et al. 153
ORGANIZATIONChiorazzo
PERSON