Epstein Secrets

tial." The Court granted the Defendant's Emergency Motion for Independent Medical Exam in accordance with that order. 16. Additionally, Plaintiff, Carolyn Andriano, sought to limit the scope of her medical examination ( as set forth in paragraph 5 above, and further sought to assert a "conditional reliance" so

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

9, 09-80591, 09-80656, 09-80802, 09-81092 ______________ / NOTICE OF FILING JOINT AGREED PROTECTIVE ORDER Plaintiffs Jane Does 2-8, Jane Doe and· Carolyn Andriano (CMA) and their counsel and Defendant Jeffrey Epstein and his counsel, in the above-styled cases hereby give Notice of Filing their Joint Agreed Pr

80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 ______________ / NOTICE OF FILING JOINT AGREED PROTECTIVE ORDER Plaintiffs Jane Does 2-8, Jane Doe and· Carolyn Andriano (CMA) and their counsel and Defendant Jeffrey Epstein and his counsel, in the above-styled cases hereby give Notice of Filing

ial." The Court granted the Defendant's Emergency Motion for Independent Medical Exam in accordance with that order. 16. Additionally, Plaintiff, Carolyn Andriano, sought to limit the scope of her medical examination ( as set forth in paragraph 5 above, and further sought to assert a "conditional reliance" so

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.

Answering Party STATE OF Florida COUNTY OF Palm Beach ) The foregoing instrument was acknowledged before me this /7 day of February, 2009 by Carolyn Andriano who is personally known to me or who has produced (type of identification) as identification and who did/did not take an oath. Notary Public St

009 Page 6 of 20 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff's Answers to Defendant's First Interrogatories 5. Jane Doe (Case No.: 1:93-cv-01109-KAM) c/o her attorney: Theodore Leopold, Esquire Leopold, Kuvin, P.A. 2925 P.G.A. Boulevard, Suite 200 Palm Beach Garde

who alleged that in her bid to find victims for Epstein, Giuffre had asked her, "Do you know any girls who are kind of slutty?"11O) The same month, Carolyn Andriano, who as a 14-year-old was introduced by Giuffre to Ghislaine Maxwell and Jeffrey Epstein and was a prosecution witness in Maxwell's trial, said in a

4-5Cr-0 A L e 13)56 StNG pitom 1.\)e<ri Pos iTICAva A December 3o, 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 Department of Justice's NPA with Epstein and his limited 2008 stat

oa, who alleged that in her bid to find victims for Epstein, Giuffre had asked her, "Do you bow any girls who are kind of shayrr-ILT The same month, Carolyn Andriano, who as a 14-year-old was introduced by Giuffre to Dhislaine Maxwell and Jeffrey Ensteiar and was a prosecution witness in Maxwell's trial, said in

oes v. United States (2014) *5 ect.) ri L Pesos r- RING, p got,4 i we.), poS ITIOOS A December 3o, 2014, federal civil suit was filed in Florida by Jane Doe 1 (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 wi

other sexual misconduct..." EFTA00190049 Epstein'. RRA, et al. Page 25 c. In her sworn FBI statement (pre-EDWARDS and RRA), L.M. testified that Carolyn Andriano, the individual who first brought L.M. to EPSTEIN's home, told L.M. I'make sure you're 18 because Jeffrey doesn't want any underage girls." (p. 8 -

OTHSTEIN, EDWARDS (who either know or should have known) and, at times, L.M. in her Civil Action against EPSTEIN: a) Included claims for damages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Organized a Jane Doe TV media interview witho