Epstein Secrets

to prevent a sexual battery and harassment victim from having to disclose off-duty sexual contacts with persons other than defendant in discovery); Herron v. Eastern Industries, Inc., 2007 WL 2781211 (N.D. Fla. Sept. 19, 2007); Gibbons v. Food Lion, Inc., 1999 WL 33226474 (M.D. Fla. Feb. 19, 1999); P.

STRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSO

to prevent a sexual battery and harassment victim from having to disclose off-duty sexual contacts with persons other than defendant in discovery); Herron v. Eastern 4 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 4 of 10 Industries, Inc., 2007 WL 2781211 (N.D. Fla

STRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSO

f’s sexual activities, Plaintiff cites to a string of employment related cases, Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996); Herron v. Eastern Industries, Inc., 2007 WL 2781211 (N.D. Fla. Sept. 19, 2007); Gibbons v. Food Lion, Inc., 1999 WL 33226474 (M.D. Fla. Feb. 19, 1999); P.J.

________________________/ 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 (

with persons other than defendant in discovery); Herron v. Eastern Industries, Inc., 2007 WL 2781211 (N.D

__________________________________/ PLAINTIFFS JANE DOE NOS. 2-8’ MEMORANDUM IN RESPONSE TO DEFENDANT’S

amendment grounds each and every question, such repeated assertions are fairly characterized as a "blanket assertion". Id.; Capitol Products Corp. Herron, 457 F.2d 541 (8th Cir. 1972). Accordingly, it is not sufficient to support the invocation of the Fifth Amendment with nothing more than sweeping

F FLORIDA CASE NO.: 08-CV-80I I 9-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

to prevent a sexual battery and harassment victim from having to disclose off-duty sexual contacts with persons other than defendant in discovery); Herron,. Eastern Industries. Inc. 2007 WL 2781211 (N.D. Fla. Sept. 19, 2007); Gibbons'. Food Lion Inc. 1999 WL 33226474 (M.D. Fla. Feb. 19, 1999); P.J. He

Interrogatory (# 18) seeking to unearth explicit information on every bit of possible sexual conduct and activity in chronological order which each Jane Doe might have engaged in since age 10, including the names and phone numbers of all persons with whom they had sexual contact.' Plaintiffs properly ob

to prevent a sexual battery and harassment victim from having to disclose off-duty sexual contacts with persons other than defendant in discovery); Herron Eastern 4 EFTA00222174 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 5 of 10 Industries. Inc. 2007 WL 2781211 (N

quest #s 10, 11, 17 and 18) requests that seek to unearth all recordings and depictions of every instance of sexual conduct and activity which each Jane Doe might have engaged and documents evidencing the names and contact information of each sexual partner over the past nine years. Plaintiffs properly