Epstein Secrets

st Seven Hours in the Aggregate Page 3 of8 degrading names such as "whore," "slut," and "cunt" ilih at 29-30; 296-298); (3) three pregnancies with Vinyard that ended in three abortions, which she failed to disclose to various physicians, including her own psychiatric expert, Dr. Kliman, and which she a

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

t on her, poured beer on her and called her degrading names such as "whore," "slut," and "cunt" (id. at 29-30; 296-298); (3) three pregnancies with Vinyard that ended in three abortions, which she failed to disclose to various physicians, including her own psychiatric expert, Dr. Kliman, and which she a

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

t on her, poured beer on her and called her degrading names such as "whore," "slut," and "cunt" (id. at 29-30; 296-298); (3) three pregnancies with Vinyard that ended in three abortions, which she failed to disclose to various physicians, including her own psychiatric expert, Dr. Kliman, and which she a

--------------'/ 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

tion 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 Jane Doe's name. Importantl

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,

ry report was filed regarding Jane Doe No. 4 and Vinyard based on an argument where he grabbed her by the

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

Doe #4 provided her former boyfriend's name, Mr. Vinyard, to her expert, Gilbert Kliman, M.D. In fact, she

began spitting on her and calling her a cheater. Jane Doe #4 also tried to bite Mr. Vinyard. See Exhibit "C"

ardner replied : "1 -.71!1 is nly dad" - Roger Gardner, Queensland I week later Paul Gardner replied: 4 '4 "Dad said yes, goceraraent approved, Vinyard approved it" -.John Howard, Australian Government -One month later: "Your saved for prostitution 'or the ntyvernlizent fluffi maize the most money

Victims' rights: Jane Does v. United States (2014) A December 30, 2014, federal civil suit was filed in Florida by Jane Doe i (Courtney Wild) and Jane Doe 2 against the United States for violations of the Crime Victims' Rights Act by the U.S. Department of Justice's NPA with Epstein and his limited 2008

and family issues. 17. There are police reports that reflect that: A. In September 2004, a battery report was filed regarding Jane Doc No. 4 and Vinyard based on an argument where he grabbed her by the neck and began spitting on her and calling ha a cheater. B. Also in September 2004, there was a d

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

and family issues. 17. There are police reports that reflect that: A. In September 2004, a battery report was filed regarding Jane Doc No. 4 and Vinyard bawd on an argument where he grabbed her by the neck and began spitting on her and calling her a cheater. B. Also in September 2004, there was a d

has met her burden, should the Court consider adopting such extraordinary relief. On its face, the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7. Discussion of Law Requiring the Denial of the Requested Protective Order Rule 26(c)(1XE), Fed.R.Civ P. (2009), gove