Epstein Secrets

osition was accordingly canceled. Two new deposition notices were then e-mailed to counsel for Bruhnel, both of which emanated from related cases in Florida Circuit Court, with no additional notice emanating from the instant matter before this Court. 2 That scheduled deposition was then canceled by agreement of the pa

ORDER TO SHOW CAUSE AND FOR AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW Non-party Jean Luc Bruhnel hereby files his Response to Plaintiff, Jane Doe’s Motion for an Order to Show Cause and for an Order to Compel and Incorporated Memorandum of Law which was filed on March 10, 2010. (DE#483). Plainti

osition was accordingly canceled. Two new deposition notices were then e-mailed to counsel for Bruhnel, both of which emanated from related cases in Florida Circuit Court, with no additional notice emanating from the instant matter before this Court. 2 That scheduled deposition was then canceled by agreement of the p

380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 NON-PARTY, JEAN LUC BRUHNEL'S RESPONSE TO PLAINTIFF JANE DOE'S MOTION FOR AN ORDER TO SHOW CAUS E AND FOR AN ORDER TO COMPEL AND 'NCO RPO RATED MEMORANDUM OF LAW Non-party Jean Luc Bruhnel hereby files his Resp

6-1CAM (S. D. Fla. 2009) Engle v. Liggett Group, Inc., 9 15 fn. 2 945 So.2d 1246 (Fla. 2006) 15 E.W. v. Epstein, Case No. 502008CA028XXXMBAB (Florida Circuit Court) 4 Gonzales v. Nat? Broad Co., Inc., 194 F.3d 29 (2d Cir. 1999) 7 In re Horowitz, 482 F.2d 72 (2s Cir. 1973) 12 In re Steinhardt Partners, L

by Playing It for Three People and Describing It in Detail to Others 11 II. ANY QUALIFIED JOURNALIST'S PRIVILEGE OF THE DAILY NEWS IS OVERCOME BY JANE DOE'S CLEAR AND COMPELLING NEED TO OBTAIN JEFFREY EPSTEIN'S OWN WORDS ABOUT HIS SEXUAL ABUSE AND LACK OF REMORSE 13 i EFTA00728062 A. The Epstein In

ee Doe #1 v. Epstein, Case No. 08-CV-80069-KAM, DE 9. Two weeks later (March 6, 2008), having changed lawyers, Jane Doe #1 refiled her complaint in Florida Circuit Court as the instant case, adding two nominal defendants Mr. Epstein's personal secretary, and MB one of Jane Doe #1's contemporaries. These defendants

eorgia before a Georgia notary), DE 4-2, Jane Doe No. I v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."). DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80

ee Doe #1 v. Epstein, Case No. 08-CV-80069-KAM, DE 9. Two weeks later (March 6, 2008), having changed lawyers, Jane Doe #1 refiled her complaint in Florida Circuit Court as the instant case, adding two nominal defendants: a, Mr. Epstein's personal secretary, and MIS, one of Jane Doe #1's contemporaries. These defe

Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLI

ee Doe #1 v. Epstein, Case No. 08-CV-80069-KAM, DE 9. Two weeks later (March 6, 2008), having changed lawyers, Jane Doe #1 refiled her complaint in Florida Circuit Court as the instant case, adding two nominal defendants: Mr= Mr. Epstein's personal secretary, and MI one of Jane Doe #1's contemporaries. These defend

eorgia before a Georgia notary), DE 4-2, Jane Doe No. I v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."), DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80

ee Doe #1 v. Epstein, Case No. 08-CV-80069-KAM, DE 9. Two weeks later (March 6, 2008), having changed lawyers, Jane Doe #1 refiled her complaint in Florida Circuit Court as the instant case, adding two nominal defendants: Mr. Epstein's personal secretary, and , one of Jane Doe #1's contemporaries. These defendants

eorgia before a Georgia notary), DE 4-2, Jane Doe No. 1 v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."), I)E 5-2, Jane Doe No. I v. Epstein, Case No. 08-8

e Doe #1 v. Epstein, Case No. 08-CV-80069-KAM, DE 9. Two weeks later (March 6, 2008), having changed lawyers, Jane Doe #1 refilled her complaint in Florida Circuit Court as the instant case, adding two nominal defendants: Mr. Epstein's personal secretary, and one of Jane Doe #1's contemporaries. These defendants ha

eorgia before a Georgia notary), DE 4-2, Jane Doe No. l v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."). DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80