Epstein Secrets

d not say "no" to Epstein. Jane Doc made a conscious decision not to have intercourse or oral sex with Epstein. Jane Doe's sexual experiences with Sprague during that same time period demonstrate that she chose to engage in those acts with him, but would not do the same with Epstein. For the same reas

93 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S MOTION PURSUANT TO FED. IL EVID. 412(c1 TO ADMIT EVIDENCE OF JANE DOE'S AND OTHER WITNESSES' SEXUAL HISTORY AND INCORPORATED MOTION FOR LEAVE TO FILE SUPPLEMENTAL MOTION PURSUANT TO RULE 412(0 REGARDING OTHER WITNESSES

14. If Jane Doe was having intercourse and oral sex with other males at the time she was allegedly going to Epstein's house, this would suggest that Jane Doc understood sex and sexuality and drew specific boundaries about what she would and would not do with Epstein. 32. It also contradicts Dr. Reed's o

regarding Jane Doe being sexually inexperienced Taira the frequency of sex with and the types of and naive, making her t " victim." Evidence of Jane Doe's relationship with demonstrates that Jane Doe sex they had. eventually became sexually experienced yet continued to go to Epstein's house. To con

s or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead,

prosecution. In each of these motions Plaintiff Jane Doe seeks to compel answers to certain requests for a

the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead, the privilege must be asserted in response to a particular question, and in each instance the burden

OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN,

ited States Constitution. Defendant’s canned objection represents a “blanket” refusal to answer questions in this civil case. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a “blanket” refusal to testify as unacceptable). While Plaintiff does not dispute that Defendant E

Attorney or State Attorney Telephone records 5-6 Videos, photographs of residence 7 Documents relating to Plaintiff Jane Doe 8 Air travel records 10 Documents relating to modeling agencies 11 Correspondence with other witnesses 14,

not of itself establish the hazard of incrimination.” Id. A “blanket refusal” to provide testimony or information is unacceptable. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). A witness bears the burden of justifying the invocation of the privilege. In re J.M.V., Inc. Epstein fall

FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN,

s or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead,

Defendant. ____________________________________/ JANE DOE, CASE NO.: 08- 80893-CIV-MARRA/JOHNSON Plain

ould be a surprise to you, based 24 upon at least what you —your impression is from 25 Justin; is that correct? Page 172 1 COURT REPORTER: And Sprague? 2 THE WITNESS: I don't know his last name — 3 MR. CRITTON: S-p-r-a-g-u-e, I believe. 4 That's how I've seen it answered in 5 interrogatories.

k with 18 them? 19 MR. EDWARDS: Object to the form. 20 THE WITNESS: Yes. Yes, l did. 21 BY MR. CRITTON: 22 Q. All right. And then it says: 'Jane Doe's 23 status as a victim of a Federal offense was confirmed 24 when she was interviewed by Federal agents on May 28th. 25 2008." Page 138 1. co

7/6/2010 Benz, Devon 58.00 Current JANE DOE JEFFREY EPSTEIN Case: 08-80893CIV-MARRA/JOHNSON Southern Ref: Doe v. Epstein 2010009677 7/8/2010 Sprague, Justin 255.88 Current JANE DOE JEFFREY EPSTEIN Case: 08.80893CIV-MARRNJOHNSON Southern Ref: Doe v. Epstein 2010009678 7/1/2010 Special., MS,

Amount Status 2010008854 6/21/2010 IMI. Surveillance, OM 7,623.51 Current INVESTIGATION Case: N/A Ref: Epstein 2010009152 6/21/2010 HIM JANE DOE JEFFREY EPSTEIN Case: 08-80893CIV4AARRA/ Southern Ref: Doe v. Epstein 2010009154 6/21/2010 JANE DOE JEFFREY EPSTEIN Case: 08-80893CIV-MARRA/.