Epstein Secrets

physical and verbal abuse by a prior boyfriend, Preston Vineyard, and deaths associated with two close friends, Ch

e deposition of Jane Doe No. 4. The deposition of Jane Doe No. 4 was to begin at 1 :00 p.m, based on her sc

tter Depositions Currently Scheduled as of October 21, 2009 Plaintiff Deponent Date and Time Location Noticed By/Court Reporter Doe 4 ( ) Preston Vineyard (By Video) 10/26/209 10:00am BCLC, Conference Room A RDC (Jess) Doe 4 10/27/09 11:00 am Prose Court Reporting 250 Australian Avenue Sout

,Kuvin Previously noticed by Edwards& Kuvin On Jane Doe & (Re- noticed) (EW) 11/05/09 10:00am Prose

y's handpicked expert, Dr. Kliman, by her own comments, her significant emotional trauma relates to physical and verbal abuse by a prior boyfriend, Preston Vineyard, and deaths associated with two close friends, Chris and Jen. Therefore, the supposed "emotional trauma" caused by a chance encounter resulting in a

sanctions pursuant to Rule 30(dX2) aril (3)(A) and (C) (referencing Rule 37(aX5)), Federal Rules of Civil Procedure and compelling the deposition of Jane Doe No. 4 within fifteen (15) days and as grounds therefore would state: 1. On August 16, 2009, the deposition of Jane Doe No. 4 was noticed for Septe

ey's handpicked expert, Dr. Taman, by her own comments, her significant emotional trauma relates to physical and verbal abuse by a prior boyfriend, Preston Vineyard, and deaths associated with two close friends, Chris and Jen. Therefore, the supposed "emotional trauma" caused by a chance encounter resulting in a

has met her burden, should the Court consider adopting such extraordinary relief. On its face, the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7. Discussion of Law Requiring the Denial of the Requested Protective Order Rule 26(c)(1XE), Fed.R.Civ P. (2009), gove