Epstein Secrets

E REQUIRED 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. So

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

overy appears reasonably calculated to lead to the discovery of admissible evidence." Id.; see also Hickman v. Taylor, 329 U.S. 495, 507-508 (1947); Farnsworth v. Proctor and Gamble Co., 758 F.2d 1545, 1547 (11th Cir. 1985)(the Federal Rules of Civil Procedure "strongly favor full discovery whenever possible

________________________/ 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 (

--- 13 v. Taylor, 329 U.S. 495, 507-508 (1947); Farnsworth v. Proctor and Gamble Co., 758 F.2d 1545, 1547 (1

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

07) (internal quotations omitted). The Federal Rules of Civil Procedure are broadly written and "strongly favor full discovery whenever possible." Farnsworth I Procter and Gamble Co., 758 F.2d 1545, 1547 (11th Cir.1985). Thus, as this Court has previously ruled in this case, the bottom line is that "[d]is

sis" for believing discoverable information exists. See In re Southeast Banking Corp, 204 F.3d 1322, 1328 (II' Cir. 2000). Accordingly, counsel for Jane Doe 1 and Jane Doe 2 represent that they have a good faith basis for seeking discovery about sex abuse committed by Alan Dershowitz in concert with Jeffre

Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights 06118-06146 09/15/2009 Seth Lehrman Bradley Edwards Farnsworth v. Marys case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evid

to lead to the discovery of the admissible evidence; protected by privacy rights 05541 07/31/2009 Carolyn Edwards Bradley Edwards All depos in Jane doe's case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

Fistos & Lehrman BATES DATE LQ FROM DESCRIPTION OBJECTION protected by privacy rights 06118-06146 09/15/2009 Seth Lehrman Bradley Edwards Farnsworth v. Macys case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evid

to lead to the discovery of the admissible evidence; protected by privacy rights 05541 07/31/2O09 Carolyn Edwards Bradley Edwards All depos in jane doe's case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr