Epstein Secrets

of party being deposed; (8) good faith of party being deposed in asking to exclude other party; and (9) any other factor deemed relevant by court. Mugrage v. Mugrage, 763 A.2d 347, 349-352 (N.J. 2000)(even when it is not appropriate to exclude the other party from the protected party's deposition, a p

t met the exceptional burden of proving to this court that Epstein should be excluded from her deposition. Plaintiff adopts and incorporates all of Jane Doe 2-S's argument with only one additional argument (i.e., that if this court allows Epstein to attend Jane Doe's deposition it would violate the right o

ending the case in the normal course of conducting discovery and filing motions would not be a breach? (Ex. "A," p.30). Mr. Horowitz - counsel for Jane Does 2-7: Subject to your rulings, of course, yes. (Ex. "A," p.30). *** The Court: But you're not taking the position that other than possibly doing s

o-feed costs, Jeffrey Epstein will not object to same. Epstein simply desires to move these cases forward and complete meaningful discovery. 5. In Mugrage v. Mugrage, 763 A.2d 347, 349-352 (N.J. 2000), the court reasoned that "[a]lthough [the wife was] in fear of [her husband], and [was] in good faith

tor is located. f. Once the deposition is over, Epstein will remain located in the room where the video- feed monitor is located until such time as Jane Doe 4 and her attorney have exited the building, which her attorney will confirm by cellular telephone with the undersigned. DONE and ORDERED this -~day

of party being deposed; (8) good faith of party being deposed in asking to exclude other party; and (9) any other factor deemed relevant by court. Mugrage v. Mugrage, 763 A.2d 347, 349-352 (N.J. 2000)(even when it is not appropriate to exclude the other party from the protected party's deposition, a pr

D MEMORANDUM OF LAW Defendant, Jeffrey Epstein, ("Epstein") by and through his undersigned counsel, serves his Response In Opposition to Plaintiff Jane Doe No. 4's Motion for Sanctions and Motion for Protective Order, With Incorporated Memorandum of Law In support, Epstein states: I. Introduction 1.