Epstein Secrets

(also found in Fed. R. Civ. P. 30(d)), Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D.W.Va. 2009) is illustrativ

______ __:! EPSTEIN'S RESPONSE IN OPPOSITION TO JANE DOE'S MOTIONS FOR PROTECTIVE ORDER BARRING SECOND DEPO

scheduled for November 13, 2009. Nevertheless, as Jane Doe's deposition will most likely occur during the we

he circumstances and result in prejudice to Epstein by denying him the opportunity to obtain discovery that is central to his defense. See Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D. W.Va. 2009)(granting the defendant an additional one day of 7 hours to depose the plaintiff, reasoning that because the plaint

656, 09-80802, 09-81092 ____________________________________/ OMNIBUS ORDER THIS CAUSE is before the Court on the following motions: (1) Plaintiff’ Jane Doe’s Motion for Protective Order Barring Second Deposition and for Sanctions (D.E. #378); and, (2) Plaintiff Jane Doe No. 4's Motion for Protective Order

n’s Motion to Compel (D.E. #s 67 & 68), which sought information related to Plaintiff’s past sexual history. All agree that there were instances at Jane Doe 4's initial deposition where she was instructed by her counsel not to answer questions “relat[ed] to sexual partners’ names or sexual positions.” Jane

ry that is central to his defense. See Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D. W.Va. 2009)(granting the d

This is based on Plaintiffs’ representation that Jane Doe’s deposition lasted 8 hours. 2 3 is necessary for a

4's deposition. 15. Although the Court waived the seven hour time limit in S.D. Fla. L.R. 26.1 K (also found in Fed. R. Civ. P. 30(d)), Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D.W.Va. 2009) is illustrative and supports Epstein's request for additional time to depose Plaintiffs. In Osborne, a personal i

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