Epstein Secrets

privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making

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

ified and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making this Case 9:08-cv-80119-KAM Document 480 Entered on FLSD Docket 03/04/2010 Page 3 of 10 4 de

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

ied and to require him to answer if it clearly appears to the Court that the witness asserting the privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-167 (6th Cir. 1983)

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,

privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making

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

ied and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making this determination the judge is instructed to view the facts and evidence presented on a case- by-c

equest as true, photographing Epstein's genitalia could potentially provide a 'lead or clue' to evidence having a tendency to incriminate. 8. In Jane Doe No. 2 v. Epstein, Case No. 08-CIV-80119 MARRA/JOHNSON, the Court sustained Epstein's Fifth Amendment objections to several interrogatories a

ied and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making this determination the judge is instructed to view the facts and evidence presented on a case- 3

e entered into a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution. In each of these motions Plaintiff Jane Doe seeks to compel answers to certain requests for admissions, interrogatories and requests for production that were propounded on Defendant Epstein.

fied and to require him to answer if it clearly appears to the Court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-167 (6th Cir. 1983) Accordingly, Plaintiff deviates where necessary from the format set forth in S.D.Fla.L.R. 26.1(H)(2) in the

Defendant and the U.S. Attorney or State Attorney 1-4 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 I 1 Correspondence with other witnesses 14, 15, 16, 17, 19 Social networking do

ied and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making this 3 EFTA00728618 Case 9:08-cv-80119-KAM Document 480 Entered on FLSD Docket 03/04/2010 Page 4

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

fied and to require him to answer if it clearly appears to the Court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-167 (6th Cir. 1983) Accordingly, Plaintiff deviates where necessary from the format set forth in S.D.Fla.L.R. 26.1(H)(2) in the

Defendant and the U.S. Attorney or State Attorney 1-4 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 I 1 Correspondence with other witnesses 14, 15, 16, 17, 19 Social networking do