Epstein Secrets

/27 /09 Deposition of Jane Doe No. 4 at 215-17); (2) repeated instances of domestic violence and physical and verbal abuse by her former boyfriend, Preston Vinyard, in which he bit her finger, spit on her, poured beer on her and called her Case 9:08-cv-80119-KAM Document 404 Entered on FLSD Docket 11/12/2

1,08-80994, 08-80993, 08-8081 I, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 _______________ / EPSTEIN'S RESPONSE IN OPPOSITION TO JANE DOE NO. 4'8 MOTION FOR PROTECTIVE ORDER AGAINST SECOND DAY OF DEPOSITION OF PLAINTIFF EXTENDING PAST SEVEN HOURS IN THE AGGREGATE Defendant, JEFFREY E

ne Doe No. 4 ["Jane Doe No. 4 Depo"] at 215-17); (2) repeated instances of domestic violence and physical and verbal abuse by her former boyfriend, Preston Vinyard, in which he bit her finger, spit on her, poured beer on her and called her degrading names such as "whore," "slut," and "cunt" (id. at 29-30; 296-2

knowing the full extent of traumatic events that may have caused or contributed to her damages could certainly skew their testimony. For example, if Jane Doe No. 4's parents are oblivious to her having three abortions, they may incorrectly attribute her alleged emotional distress to Mr. Epstein when, in f

ne Doe No. 4 ["Jane Doe No. 4 Depo"] at 215-17); (2) repeated instances of domestic violence and physical and verbal abuse by her former boyfriend, Preston Vinyard, in which he bit her finger, spit on her, poured beer on her and called her degrading names such as "whore," "slut," and "cunt" (id. at 29-30; 296-2

--------------'/ EPSTEIN'S RESPONSE IN OPPOSITION TO JANE DOE NO. 4'S MOTION FOR PROTECTIVE ORDER AS TO THE SCOPE OF INQUIRY AT THE DEPOSITIONS OF JANE DOE NO. 4'S PARENTS AND INCORPORATED MOTION TO STRIKE Defendant, JEFFREY EPSTEIN ("Epstein"), submits this Response in Opposition to Plaintiff's, Jane

Jeffrey Epstein. (i) The Declaration of Jane Doe Number #4 9. As to Jane Doe #4' s declaration, investigators interviewed her former boyfriend, Preston Vinyard, by telephone. Mr. Vinyard commented that he knew the investigators wanted information about Jane Doe #4 without the investigators even mentioning

ue to her husband's position of employment, which appeared to be with a particular fire department. Investigators asked Y .B to discuss her sister, Jane Doe #4; however, at approximately 2:49 p.m., Y.B. abruptly ended the conversation and led her husband back inside the home. Nothing further was discussed,

hock for approximate! y 2 months. Ex. "D" at 'll'l!17 & 19. On 10/31/04, Plaintiff, while intoxicated, had an altercation with her then boyfriend, Preston Vinyard. Ex. "D" at 'l[21. When the Police arrived, they found Plaintiff in her home with no shirt on; and Plaintiff refused to cooperate with the police

CASE NO.: 08-80811-CIV-MARRA/JOHNSON ___________ .! 2 Case 9:08-cv-80119-KAM Document 247 Entered on FLSD Docket 08/05/2009 Page 3 of 19 JANE DOE, Plaintiff, JEFFREY EPSTEIN et al, Defendants. CASE NO.: 08-80893-CIV-MARRA/JOHNSON -----------~' DOE II, Plaintiff, JEFFREY EPSTEIN et al,

ng body image problems; B. Had an ex-boyfriend, Preston Vinyard, who was, on information and belief, a drug deal

ion for No-Contact Order (DE 113) and Plaintiffs Jane Does' 2-7 Notice of Joinder in Plaintiffs' Motion (DE

606.46 Jane Doe #4 Dr. Hall's time: Records reviewed: Deposition transcripts of Jane Doe 4, dated 10/27/09 and 02/12/10 Deposition transcript of Preston Vinyard, dated 10/26/09 04/28/10 Review, annotate, highlight, and dictate records 2 hr 05/02/10 Review, annotate, highlight, and dictate records 2 hr 3

ltation with attorney 51 min Total hours Rate: $400/hour 1 hr 41 min Jane Doe #2 Dr. Hall's time: Records reviewed: Deposition transcripts of Jane Doe 2, dated 03/03/0 Deposition exhibits Medical records of The Virginia League for Planned Parenthood Therapy records of Marilyn Spiro, PhD Medical r

PLEASE TAKE NOTICE that the undersigned attorney will serve a Subpoena on and take the deposition of: DEPONENT DATE & TIME LOCATION OF DEPOSITION Preston Vinyard October 26, 2009 Burman Critton Luttier & Coleman, 902 96 Court at 10:00 AM LLC Palm Beach Gardens, FL 33410 303 Banyan Blvd., Suite #400 Wes

, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 NOTICE OF TAKING VIDEOTAPED DEPOSITION AS TO JANE DOE #4 PLEASE TAKE NOTICE that the undersigned attorney will serve a Subpoena on and take the deposition of: DEPONENT DATE & TIME LOCATION OF DEPOSIT

606.46 Jane Doe #4 Dr. Hall's time: Records reviewed: Deposition transcripts of Jane Doe 4, dated 10/27/09 and 02/12/10 Deposition transcript of Preston Vinyard, dated 10/26/09 04/28/10 Review, annotate, highlight, and dictate records 2 hr 05/02/10 Review, annotate, highlight, and dictate records 2 hr 3

onsultation with attorney 1k Total hours Rate: $400/hour 1 hr 41 min Jane Doe #2 Dr. Hall's time: Records reviewed: Deposition transcripts of Jane Doe 2, dated 03/01/0 Deposition exhibits Medical records of The Virginia League for Planned Parenthood Therapy records of Marilyn Spiro, PhD Medical r

cally with regard to her father. She described herself as being angry, bitter, depressed and having body image problems; B. Had an ex-boyfriend, Preston Vinyard, who was, on information and belief. a drug dealer who she lived with; C. Had drug and alcohol problems herself; and 09/12/2019 PI 949 CONFIDEN

sanctions pursuant to Rule 30(dX2) aril (3)(A) and (C) (referencing Rule 37(aX5)), Federal Rules of Civil Procedure and compelling the deposition of Jane Doe No. 4 within fifteen (15) days and as grounds therefore would state: 1. On August 16, 2009, the deposition of Jane Doe No. 4 was noticed for Septe