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23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): Th
________ / Defendant's Response In Opposition to Jane Doe 2-8s Motion to Compel Net Worth Discovery, With
United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, I 50-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited
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
23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): Th
EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE, MOTION TO COMPEL RESPONSE TO PLAINTIFF'S REQUES
United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited
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
ited States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited o
l recording or other audio or video depiction or image of the Palm Beach Residence. Request No. 8. All documents referring or relating to Plaintiff Jane Doe No. 2, including without limitation, web pages, social networking site pages, correspondence, videotapes and audiotapes. Request No. 9. (Not at is
nited States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited o
ing these protections meaningless in attempting EFTA00222075 Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 2 of 37 Jane Doe No. 2 v. Epstein Page 2 to assert and argue the factual basis for the additional objections and privileges. See part ILA. herein. I. Defendant E
United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited
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
Entities connected to both Shaktman and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSON
Ghislaine Maxwell
PERSON
Salt Lake City
LOCATIONScott Rothstein
PERSONRobert C. Josefsberg
PERSONJack Scarola
PERSONKatherine W. Ezell
PERSONRichard Horace Willits
PERSONJack Patrick Hill
PERSONIsidro Manuel Garcia
PERSON