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Fla. 2008) (citing cases relying upon Maddow v. Procter & Gamble Co., 107 F.3d 846 (11th Cir. 1997), in rejecting a h
FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPS
formation may be obtained by a party in discovery.” Bellosa v. Universal Tile Restoration, Inc., 2008 WL 2620735 (S.D. Fla. 2008) (citing Maddow v. Procter & Gamble Co., 107 F.3d 846 (11th Cir. 1997)); accord U.S. v. Certain Real Property, 444 F.Supp. 2d 1258 (S.D.Fla. 2006); Platypus Wear, Inc. v. Clarke Modet & C
FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPS
TO APPEAR FOR DEPOSITION MORE THAN ONCE The district court has discretion to fashion a protective order under Fed.R.Civ.P. 26(c). Farnsworth v. Procter & Gamble Co., 758 F.2d 1545 (11th Cir. 1985). This discretion “does not depend upon a legal privilege.” Id.; Auto Owners Ins. Co. v. Southeast Floating Docks,
t the Defendant sexually assaulted the plaintiff when she was a minor. This Motion is prompted by the Defendant’s efforts to take the deposition of Jane Doe No. 3 as a witness in this case. Defendant, however, does not at this time seek to take Jane Doe No. 3’s deposition in her own case. The Defendan
08 WL 2620735 (S.D. Fla. 2008) (citing Maddow v. Procter & Gamble Co., 107 F.3d 846 (11th Cir. 1997)); accord U.S. v.
FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPS
they have reason to believe certain indictments will issue. United States I Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States I Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained in Petitioners' submission contain allegations related to matters occurring befo
empting to negotiate with the government for more than 30 months. As set forth in the Procedural History Section of the United States' Opposition to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victim Rights Act ("CVRA"), at the last hearing on the Petitioners' Emergency Pet
hey have reason to believe certain indictments will issue. United States v. Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained in Petitioners' submission contain allegations related to matters occurring befo
empting to negotiate with the government for more than 30 months. As set forth in the Procedural History Section of the United States' Opposition to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victim Rights Act("CVRA"), at the last hearing on the Petitioners' Emergency Peti
they have reason to believe certain indictments will issue. United States I Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States I Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained in Petitioners' submission contain allegations related to matters occurring befo
empting to negotiate with the government for more than 30 months. As set forth in the Procedural History Section of the United States' Opposition to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victim Rights Act("CVRA"), at the last hearing on the Petitioners' Emergency Peti
iscovery of information from the investigation that is relevant to the CVRA claim— specifically the issue of probable cause. See,e.g.,Farnsworth v. Procter & Gamble Co., 758 F.2d 1545, 1546 (11th Cir. 1985) ("The law's basic presumption is that the public is entitled to every person's evidence. The Federal Rules o
30 underage girls whom he sexually abused at his mansion in Palm Beach, Florida. The victims la ded one of the initial petitioners in this case, (Jane Doe I), who was 15 years old when Epstein first sexually abused her. Following the FBI's investigation, the U.S. Attorney's Office for the Southern Di
Entities connected to both Procter & Gamble Co. and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONRobert D. Critton
PERSON
George W. Bush
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSONRobert C. Josefsberg
PERSON
Department of Justice
ORGANIZATIONKatherine W. Ezell
PERSONRichard Horace Willits
PERSON
Virginia Giuffre
PERSONJack Patrick Hill
PERSONIsidro Manuel Garcia
PERSONStuart S. Mermelstein
PERSONMermelstein & Horowitz
ORGANIZATION