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cham v. City of West Sacramento, 2009 WL 689729 (E.D. Cal. 2009) Memorandum of Law In support of Motion 15
, her lawyer now claims that Epstein "terrorized Jane Doe No. 3 by crossing paths with her .... " as he ex
1, 2010); U.S. v. Renga, 2009 WL 2579103, fn. I (E.D. Cal. Aug. 19, 2009); U.S. v. Ferenci, 2009 WL 2579102
testimony, she was brought by another minor girl (Jane Doe No. 3) to EPSTEIN's Palm Beach home the one time
ld be upheld. Allen v. Woodford, 2007 WL 309485 (E.D. Cal. 2007), (p. 9)(HIPP A institutes procedural safegu
EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE, MOTION TO COMPEL RESPONSE TO PLAINTIFF'S REQUES
ealth Insurance Portability and Accountability Act) objection, as noted in the case cited in Plaintiff's motion, Allen v. Woodford, 2007 WL 309485 (E.D. Cal. 2007), (p. 9), HIPPA institutes procedural safeguards to protect the privacy of an individual's medical information and history. In the context of
l recording or other audio or video depiction or image of the Palm Beach Residence. Request No. 8. All documents referring or relating to Plaintiff Jane Doe No. 2, including without limitation, web pages, social networking site pages, correspondence, videotapes and audiotapes. Request No. 9. (Not at is
govern the minimum statutory damage amount ($50,000 rather than $150,000) under ex post facto laws, see United States v. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black. Srebnick. Komspan & Stumpf.
se to our requests during our meeting of February 3. Since February 11, 2010, a lawsuit has been filed by the attorney representative on behalf of Jane Doe 103. Her identity is known by us and she is on the "identified list." Hcr lawsuit raises only §2255 claims. Although she has not waived her right
govern the minimum statutory damage amount ($50,000 rather than $150,000) under ex post facto laws, see United States v. Scheidt 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black. Srebnick. Komspan & Stump& P
se to our requests during our meeting of February 3. Since February 11, 2010, a lawsuit has been filed by the attorney representative on behalf of Jane Doe 103. Her identity is known by us and she is on the "identified list." Her lawsuit raises only §2255 claims. Although she has not waived her right
govern the minimum statutory damage amount ($50,000 rather than $150,000) under ex post facto laws, see United States'. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black. Srebnick. Komspan & Stump& P
se to our requests during our meeting of February 3. Since February 11, 2010, a lawsuit has been filed by the attorney representative on behalf of Jane Doe 103. Her identity is known by us and she is on the "identified list." Her lawsuit raises only §2255 claims. Although she has not waived her right
govern the minimum statutory damage amount (t50,000 rather than $150,000) under ex post facto laws, see United States I. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black, Srebnick. Komspan & Stumpf,
se to our requests during our meeting of February 3. Since February 11, 2010, a lawsuit has been filed by the attorney representative on behalf of Jane Doe 103. Her identity is known by us and she is on the "identified list." Her lawsuit raises only §2255 claims. Although she has not waived her right
) govern the minimum statutory damage amount ( 50,000 rather than $150,000) under ex post facto laws, see United States Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black. SrebnIck, Kornspan & Stumpf.
you have asked us to provide such an advisory opinion. The request relates to Mr. Epstein's Motion to Dismiss in toto the suit filed against him by Jane Doe 103, whom we understand is one of the victims identified through the 2006 through 2007 investigation that culminated in the signing of the Non-Prose
Entities connected to both E.D. Cal. and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSONMaria Farmer
PERSONRobert D. Critton
PERSON
George W. Bush
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSONLeon Black
PERSON
Alexander Acosta
PERSON
A. Marie Villafana
PERSONRobert C. Josefsberg
PERSON
Department of Justice
ORGANIZATIONKatherine W. Ezell
PERSONRoy Black
PERSON
Jay Lefkowitz
PERSONStuart S. Mermelstein
PERSON