Epstein Secrets

of North America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007); State Farm v

[email protected] Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger &

tress," such claims are subject to the constitutional limitations and guideposts as set forth in BMW of North America v. Gore 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007); State Farm v. Campbell, 123 S.Ct 1513 (2003). Engle v. Liqqet Group, Inc., 945 So.2d 1246 (Fla. 2006). The Due

PLAINT IDE 24, 12/14/091 Defendant JEFFREY EPSTEIN, (EPSTEIN), by and through his attorneys, files his answer and affirmative defenses to Plaintiff JANE DOE No. 8's Amended Complaint, dated December 12, 2009 [DE 24], and states: 1. Without knowledge and deny. 2. As to the allegations in paragraphs 2, D

ress," such claims are subject to the constitutional limitations and guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams 127 S.Ct. 1057 (2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Liqoet Group, Inc., 945 So.2d 1246 (Fla. 2006). The Due P

d Evidence §592. Defendants in civil actions. - EFTA00221236 Case 9:08-cv-80993-KAM Document 86 Entered on FLSD Docket 06/10/2009 Page 2 of 10 Jane Doe No. 7 v. Epstein Page 2 .. a civil defendant who raises an affirmative defense is not precluded from asserting the privilege [against self-incrimi

ress,° such claims are subject to the constitutional limitations and guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Ligget Group, Inc., 945 So.2d 1246 (Fla. 2006). The Due

. Defendants in civil actions. - EXHIBIT Pt EFTA00221246 Case 9:08-cv-80232-KAM Document 115-2 Entered on FLSD Docket 06/09/2009 Page 2 of 10 Jane Doe No. 3 v. Epstein Page 2 "... a civil defendant who raises an affirmative defense is not precluded from asserting the privilege [against self-incri

ress," such claims are subject to the constitutional limitations and guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007); State Farm v. Campbell 123 S.Ct 1513 (2003); Engle v. Liqqet Group, Inc., 945 So.2d 1246 (Fla. 2006). The Due P

d Evidence §592. Defendants in civil actions. - EFTA00221260 Case 9:08-cv-80994-KAM Document 71 Entered on FLSD Docket 06/10/2009 Page 2 of 10 Jane Doe No. 6 v. Epstein Page 2 "... a civil defendant who raises an affirmative defense is not precluded from asserting the privilege [against self-incri

ress," such claims are subject to the constitutional limitations and guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Liqoet Group, Inc., 945 So.2d 1246 (Fla. 2006). The Due

ould ultimately result in reversible error at any trial. II. Conclusion and Prayer for Relief 22. Epstein requests the following relief: a. That JANE DOE's Motion to Proceed Anonymously be denied; b. That this Court grant Epstein's Motion and that JANE DOE be identified by her legal name in the style