Epstein Secrets

ndants to talk to prosecutors without sacrificing their ability to defend themselves if no disposition agreement is reached"); Fed. R. Crim. P. 11, Advisory Committee Notes, 1979 Amendment ("the purpose of Fed. R. Ev. 410 and Fed. R. Crim. P. 11(eX6) [now Rule 11(f)] is to promote the unrestrained candor which pr

Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 4 of 37 Doe v. Epstein 08-CV80119 Page No. 4 (a) Jane Doe Plaintiff, Jane Doe's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth therein are incorporated

e, if this court rules that any of the information requested herein should be produced (e.g., Requests Numbers 12 and 13 (tax returns and passport — Jane Doe) and Request Number 1 (tax returns-Jane Doe 2-8)), it shall only do so after an in camera hearing allowing the documents to be reviewed and placed o

that a therapist s ability to help a patient is completely dependent upon the patient s willingness and ability to talk freely. Id. at 10, quoting Advisory Committee s Notes to Proposed Rules, 56 EFTA00301916 F.R.D. 183, 242 (1972). The Court found that the psychotherapist- patient privilege is rooted in the im

Intervenor Jeffrey Epstein s Motion For a Protective Order And Opposition to Motions of Jane Doe 1 And Jane Doe 2 For Production, Use, And Disclosure Of Plea Negotiations Jeffrey Epstein opposes the motion of Jane Doe 1 and Jane Doe 2 for dislcosure of all the

ered would be relevant under the facts and theories of the particular case and cannot be obtained except through discovery." See Fed. R. Evid. 412, Advisory Committee Notes to 1994 Amendments, subdivision (c). Defendant has made no such showing in his Motion to Compel to overcome this presumption. Accordingly, Def

Interrogatory (# 18) seeking to unearth explicit information on every bit of possible sexual conduct and activity in chronological order which each Jane Doe might have engaged in since age 10, including the names and phone numbers of all persons with whom they had sexual contact.' Plaintiffs properly ob

ndants to talk to prosecutors without sacrificing their ability to defend themselves if no disposition agreement is reached"); Fed. It Crim. P. 11, Advisory Committee Notes, 1979 Amendment ("the purpose of Fed. R. By. 410 and Fed. R. Crim. P. 11(eX6) [now Rule 11(01 is to promote the unrestrained candor which pro

des Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. §2255, one of the principal causes of action in the Jane Doe cases. This opinion work product should not be disclosed when it was incorporated into heartland plea negotiations that are accorded protection und

cal Society TNG for Psychology, 2006-08 Social Sciences Research Council: Committee on Cognition and Surveys, 1985-90 Bureau of National Affairs, Advisory Committee on Complex Litigation, 1987-1990 Representative from University Faculty to State Legislature, 1976-78 Advisory Comm., Institute of Government and P

Balancing with the players stacked against you. Applied Cognitive Psychology, 16, 365-366 (Book Review). Loftus, E.F. & Guyer, M. (2002) Who Abused Jane Doe?: The Hazards of the Single Case History. Skeptical Inquirer. Part I. Vol 26, #3 (May/June), Pp. 24-32. Loftus, E. F. & Guyer, M. J. (2002) Who Abu

the United States, 1979-1980 Committee on Abuse and Misuse of Psychiatry and Psychiatrists in the United States, 1980-1987 (Chairman, 1984-1986) Advisory Committee on the Paraphilias, Task Force on Nomenclature and Statistics (DSM-III-R), 1985-1987 Advisory Committee on Disorders of Impulse Control Not Elsewhe

k, New York) [2nd Circuit Opinion: 938 F.2d 1535 (2nd Cir. 1991)] Testified at deposition, 5/13/90 Testified in court (trial or hearing), 5/14/90 Jane Doe v. Stuart Brown. M.D. (San Diego, California) Testified by deposition, 6/6/90 Carin Evans vs. Richard Benton, Ph.D. (Houston, Texas) Testified at

ion rinstdeten- tion *1033 (United States Provenzano, 605 F.2d 85, 94 (3d Cir.1 9)), in 1972 Fed.R.App. ("Rule 9(c) was adopted ex- pressly (1972 Advisory Committee Notes to that Rule): to allocate to the defendant the burden of establishing that he will not flee and that he poses no danger to any other perso

8's eighteenth birthday, and when Jane Doe #19 was seventeen years old. [NB: The police report describes a pattern of activity, including dates when Jane Doe #18 was seventeen years old.] Neither Jane Doe #18 nor #19 ever returned to Epstein's home. Although we have not yet obtained Jane Doe #18's teleph