Epstein Secrets

othing more than a vague and contentless statement that the materials are "likely to lead to the discovery of other admissible evidence." Motion to Compel at 12 n.3, which is all that plaintiff offers as to Request No. 10. This is particularly so given the reality that parties often take positions or o

des Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. §2255, one of the principal causes of action in the Jane Doe cases. This opinion work product should not be disclosed when it was incorporated into heartland plea negotiations that are accorded protection und

interrogatory is "harassing,' "outrageous, offensive and is apparently posed for the purpose of intimidating Plaintiff." See Defendant's Motion to Compel directed to Plaintiff's Answers to Defendant's First Set of Interrogatories, addressing identical discovery issues. Both Defendant's interrogatories

0119-MARRA.JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. ----------------'' DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE & TO OVERRULE OBJECTIONS, & FOR AN AWARD OF DEFENDANT'S REASONABLE EXPENSES Defendant,

ents, subdivision (c). Defendant has made no such showing in his Motion to Compel to overcome this presumption. Accordingly, Defendant’s Motion to Compel must be denied in its entirety. Defendant also seeks in Request #1 “all tax returns and supporting documentation” dating back to 2002. Plaintif

STRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSO

he Court were to grant Jane Doe No. 4's Motion, it would essentially be punishing Epstein for timely proceeding with discovery while his Motions to Compel (DE #s 67 & 68) related to past sexual history were still pending, which 1 Despite Jane Doe No. 4's assertion that "[t]he nature of this case, for d

1,08-80994, 08-80993, 08-8081 I, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 _______________ / EPSTEIN'S RESPONSE IN OPPOSITION TO JANE DOE NO. 4'8 MOTION FOR PROTECTIVE ORDER AGAINST SECOND DAY OF DEPOSITION OF PLAINTIFF EXTENDING PAST SEVEN HOURS IN THE AGGREGATE Defendant, JEFFREY E

othing more than a vague and contentless statement that the materials are "likely to lead to the discovery of other admissible evidence." Motion to Compel at 12 n.3, which is all that plaintiff offers as to Request No. 10. This is Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2

ocket entries. Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 4 of 37 Doe v. Epstein 08-CV80119 Page No. 4 (a) Jane Doe Plaintiff, Jane Doe's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth t

ERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of time of until May 6, 2009, to respond to the Defendant's Motions to Compel, et al. DONE AND ~RD ED in Chambers, at West Palm Beach, Palm Beach County, Florida, h• / d f UNG O tis_ ayo ,209. -/ ~ L c;:;;><- ,_,_.

Entered on FLSD Docket 06/02/2009 Page 1 of 2 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

9, 2009, to respond to the Defendant's Motions to Compel, et al. DONE AND ORDERED in Chambers, in Zt ~~L~

Entered on FLSD Docket 04/27/2009 Page 1 of 2 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend