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es v. Benfield, 593 F.2d 815 (8th Cir.1979). Importantly, there are no minor Plaintiffs in this matter or the related matters. All are of age. 5. Moroever, I McCormick on Evid., §19 (6th ed.) states, in pertinent part, that: "[f]or two centuries, common law judges and lawyers have regarded the opportun
t met the exceptional burden of proving to this court that Epstein should be excluded from her deposition. Plaintiff adopts and incorporates all of Jane Doe 2-S's argument with only one additional argument (i.e., that if this court allows Epstein to attend Jane Doe's deposition it would violate the right o
ending the case in the normal course of conducting discovery and filing motions would not be a breach? (Ex. "A," p.30). Mr. Horowitz - counsel for Jane Does 2-7: Subject to your rulings, of course, yes. (Ex. "A," p.30). *** The Court: But you're not taking the position that other than possibly doing s
dence pertaining to the alleged events. (DE 242). Moroever, the requested information could encompass docum
EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE, MOTION TO COMPEL RESPONSE TO PLAINTIFF'S REQUES
tes v. Benfield, 593 F.2d 815 (8th Cir.1979). Importantly, there are no minor Plaintiffs in this matter or the related matters. All are of age. 5. Moroever, 1 McCormick on Evid., §19 (6th ed.) states, in pertinent part, that: "[flor two centuries, common law judges and lawyers have regarded the opportun
D MEMORANDUM OF LAW Defendant, Jeffrey Epstein, ("Epstein") by and through his undersigned counsel, serves his Response In Opposition to Plaintiff Jane Doe No. 4's Motion for Sanctions and Motion for Protective Order, With Incorporated Memorandum of Law In support, Epstein states: I. Introduction 1.
Entities connected to both Moroever and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSONMaria Farmer
PERSONRobert D. Critton
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSON
Salt Lake City
LOCATIONScott Rothstein
PERSON
A. Marie Villafana
PERSONRobert C. Josefsberg
PERSONJack Scarola
PERSONKatherine W. Ezell
PERSONRichard Horace Willits
PERSONJack Patrick Hill
PERSONIsidro Manuel Garcia
PERSON
Sarah Kellen
PERSONMermelstein & Horowitz
ORGANIZATION