Epstein Secrets

4/28/2010 Page 5 of 9 overly broad, burdensome or oppressive, by submitting evidence or offering evidence which reveals the nature of the burden." Coker v. duke & Co .. , 1777 F.R.D. 682, 686 (M.D. Ala. 1998). Plaintiff has failed to make such a showing. Therefore, her Motion for Protective Order sh

fected them emotionally and psychologically. See ~-, Exhibit "D", Affidavit of Richard C.W. Hall, outlining the psychological issues experienced by Jane Doe 4 as a result of incidents in her life prior to Epstein, which cannot be discounted. As such, Plaintiffs should not, once again, be able to "handpic

an permeate everything: your sense of self, intimate relationships, sexuality, parenting, working, even your sanity.”)4 The U.S. Supreme Court in Coker v. Georgia, 433 U.S. 584, 597 (1977), discussed the grave nature of the crimes at issue in the cases against Defendant, stating: [Rape] is highly r

DOE, CASE NO.: 08-CV-80893-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ JANE DOE NO. II, CASE NO.: 08-CV-80469- MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ___________________________________

w a discovery request is overly broad, burdensome or oppressive, by submitting evidence or offering evidence which reveals the nature of the burden.” Coker v. Duke & Co., 1777 F.R.D. 682, 686 (M.D. Ala. 1998). Once the resisting party meets its burden, the burden shifts to the moving party to show the i

________________________/ OMNIBUS ORDER THIS CAUSE is before the Court on the following motions: (1) Defendant Epstein’s Motion to Compel Plaintiff Jane Doe 2 to Respond to Defendant’s First Request to Produce and to Overrule Objections and For an Award of Defendant’s Reasonable Expenses (D.E. #67); and (

3 N.Y.S.2d 872 (N.Y.City Civ.Ct.1992)); see also Coker v. Georgia, 433 U.S. 584, 597, 97 S.Ct. 2861, 53

endant. ____________________________________/ JANE DOE, CASE NO.: 08- CV-80893-MARRA/JOHNSON P

evidence which reveals the nature of the burden.” Coker v. Duke & Co., 1777 F.R.D. 682, 686 (M.D. Ala. 19

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

a discovery request is overly broad, burdensome or oppressive, by submitting evidence or offering evidence which reveals the nature of the burden." Coker v. Duke & Co., 1777 F.R.D. 682, 686 (M.D. Ala. 1998). Once the resisting party meets its burden, the burden shifts to the moving party to show the

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

a discovery request is overly broad, burdensome or oppressive, by submitting evidence or offering evidence which reveals the nature of the burden." Coker v. Duke & Co., 1777 F.R.D. 682, 686 (M.D. Ala. 1998). Once the resisting party meets its burden, the burden shifts to the moving party to show the

Y EPSTEIN, Defendant. CASE NO.: 08-80993-CIV-MARRA/JOHNSON , Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80811-CIV-MARRA/JOHNSON JANE DOE, CASE NO.: 08- 80893-CIV-MARRNJOHNSON Plaintiff, vs. JEFFREY EPSTEIN et al, 2 EFTA00728595 Case 9:08-cv-80119-KAM Document 242 Entered on F

f South Alabama I American Tobacco Co., 168 F.3d 405, 411 (11th Cir. 1999) (citing Bums. Windsor Ins. Co., 31 F.3d 1092, 1095 (11th Cir. 1994), and Coker. Amoco Oil 3 EFTA00234426 Case 9:08-cv-80804-KAM Document 11 Entered on FLSD Docket 08)18:2008 Page 4 of 11 Co., 709 F.2d 1433 (11th Cir. 198

1 Entered on FLSD Docket 08)18:2008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a, JANE DOE NO. I, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. MOTION TO REMAND Plaintiff Jane Doe moves the Court to remand this act

on against any one of the resident defendants, the federal court must find that joinder was proper and remand the case to state court." Id. quoting Coker,. Amoco Oil Co., 709 F.2d 1433, 144041 (11th Cir.1983). The Florida Fifth District Court of Appeals set forth the elements of a civil conspiracy as

led by Jeffrey Epstein. (Tein, Michael) (Entered: 09/05/2008) 09/15/2008 22 r 3" KB REPLY to Response to Motion re 11 MOTION to Remand filed by Jane Doe. (Kuvin, Spencer) (Entered: 09/15/2008) 09/16/2008 21 r 893 KB NOTICE of Substitution of Counsel by Theodore Jon Leopold on behalf ofJane Doe (

McKinney's Sessions Laws of N.Y., a! 2211-2212 (quoted in Deborah S. v. Diorio, 153 Misc.2d 708, 583 N.Y.S.2d 872 (N.Y.City Civ.Ct.1992)); see also Coker'. Georgia, 433 U.S. 584, 597, 97 S.G. 2861, 53 L.Ed.2d 982 (1977) ("Short of homicide, [rape] is the ultimate violation of self'). As to the fourth

public disclosure of the victims' identities in these cases, and allowed the Plaintiff in that case to "proceed in this action under the pseudonym 'Jane Doe' ", by Order dated October 6, 2008. 7. Jeffrey Epstein sets forth no facts to support his bare contention that Jane Does 2- 7 use of a pseudonym in