Epstein Secrets

155, 170, 181, 184-187, 192, 198-202, 205-206, 208-210, 212, 215-217; Exhibit 1. Forty years ago, the Florida Supreme Court, in Surf Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970), gave this general definition of work product saying what it is and what it is not: [T]hose documents, pictures,

you represented Jane Doe. .. whether she was considered a victim by the U.S. Attorney's Office?" and then re-phrased: ". . .[D]id you learn whether [Jane Doe 1] was listed as a, or deemed to be a victim by the U.S. Attorney's Office?" Id. at 100-104. Although contrary to law, Mr. Scarola's stated position

ROLA: I am going to object. That calls for attorney-client privilege. 100/9-14 Q. At the time do you know whether, at the time that you represented Jane Doe 1, do you know whether her name, whether she was considered a victim by the United States Attorney's Office? 100/15-23 A. SCAROLA: If that informati

hood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1); see also Surf Drugs. Inc .. v. Vermette, 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), ci

CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. I ------------- MOTION TO COMPEL AND/OR IDENTIFY JANE DOE IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY, OR ALTERNATIVELY, MOTION TO DISMISS

ihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1); see also Surf Drugs, Inc., v. Vermette, 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), ci

ury and justice shall be administered without sale, denial or delay. Art. I, §21, Fla. Const.; 10A Fla. Jur. 2d, Constitutional Law, §360. 16. If Jane Doe's name is not disclosed and identified, Mr. Epstein will not be afforded his fundamental right to fairly litigate this dispute and prepare for trial.

ihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1). see also Surf Drugs, Inc., v. Vermette 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), cit

ury and justice shall be administered without sale, denial or delay. Art. I, §21, Fla. Const.; 10A Fla. Jur. 2d, Constitutional Law, §360. 15. If Jane Doe's name is not disclosed and identified, Mr. Epstein will not be afforded his fundamental right to fairly litigate this dispute and prepare for trial.

ihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1); see also Surf Drugs. Inc., v. Vermette, 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), ci

ould ultimately result in reversible error at any trial. II. Conclusion and Prayer for Relief 22. Epstein requests the following relief: a. That JANE DOE's Motion to Proceed Anonymously be denied; b. That this Court grant Epstein's Motion and that JANE DOE be identified by her legal name in the style