Epstein Secrets

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

s and the defenses in the litigation"). W. The information simply falls under the "highly protected category of opinion work-product." Id; see also Fla.R.Civ.Pro. 1.280. Also, Counsel for Jane Does 2-8 in the Federal companion cases apparently obtained a copy of the file retained by the Palm Beach State

9 A. I didn't tell you that. 10 Q. Okay. Let me ask you then: Did you ever 11 use Qtask, you personally create a project as it 12 related to Jane Doe's case against Mr. Epstein? A. No. 14 Q. To your knowledge did you direct anyone 15 well, let me strike that. Did you direct anyone to 16 crea

A00599740 Page 80 A. I'm finished. 2 Q. Which case was he the referring lawyer, Mr. Howell? 4 A. Q. And he may be the referring lawyer on Jane 6 Doe, and ., you just don't know as you sit here, 7 or he is? 8 A. He referred .'s case. 9 Q. And the other two cases is he is shown as 10 the

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2009CA040800XXXXMB AG Complex Litigation, Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, -vs- VOLUME I OF II SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and III. individual

l. 18. On or before July 1, 2010, you arranged for a private investigator to 19. The private investigator hired by you to conduct surveillance on Jane Doe 20. When you filed this lawsuit against Bradley J. Edwards, you knew that it had no basils in fact. 4 EFTA00722356 09/18/2010 15:16 PAZ SEARCY

ff'Counterdefendant, JEFFREY EPSTEIN, and requests that PlaintiffiCountenlefendant admit or deny the following facts, in accordance with Rule 1.370, Fla.R.Civ.P.: ADMISSIONS 1. You have acted on a sexual preference for minor females' on multiple occasions over the course of at least the last decade. 2.

r should have known that Rothstein was scrupulously marketing alleged Epstein settlements based upon the lawsuits filed by three (3) Jane Does (Le., Jane Doe, LM and EW). Jane Doe is filed in the Southern District of Florida, and LM and EW are both filed in the Circuit Court in and for Palm Beach county,

vidence that would be inadmissible at trial, so long as it is reasonably calculated to lead to the discovery of admissible evidence. Rule 1.280(b), Fla.R.Civ.P. (2008). Wherefore, Epstein requests that this court grant the relief requested herein, including, but not limited to, ordering that Edwards retu

r should have known that Rothstein was scrupulously marketing alleged Epstein settlements based upon the lawsuits filed by three (3) Jane Does (Le., Jane Doe, LM and EW). Jane Doe is filed in the Southern District of Florida, and LM and EW are both filed in the Circuit Court in and for Palm Beach county,

vidence that would be inadmissible at trial, so long as it is reasonably calculated to lead to the discovery of admissible evidence. Rule 1.280(b), Fla.R.Civ.P. (2008). Wherefore, Epstein requests that this court grant the relief requested herein, including, but not limited to, ordering that Edwards retu

Defendant and the U.S. Attorney or State Attorney 1-4 Telephone records 5-6 Videos, photographs of residence 7 Documents relating to Plaintiff Jane Doe 8 Air travel records 10 Documents relating to modeling agencies I 1 Correspondence with other witnesses 14, 15, 16, 17, 19 Social networking do

ation of health care providers telephone numbers used by Epstein and his employees general information based on Florida Standard Interrogatories, Fla.R.Civ.P. Form 2, nos. 7, 10, 12 I, 2, 3, 4, 5, 6, 10, 17 7 8 II, 12 13, 14, 164 These Interrogatories, on their face, do not infringe upon or otherwi

N Defendant. Plaintiff. JEFFREY EPSTEIN Defendant. CASE NO.: 08-80993-CIV-MARRA/JOHNSON CASE NO.: 08-80811-CIV-MARRA/JOHNSON 2 EFTA00729245 JANE DOE, Plaintiff, JEFFREY EPSTEIN et al, Defendants. CASE NO.: 08-80893-C1V-MARRA/JOHNSON DOE II, Plaintiff, JEFFREY EPSTEIN et al, Defendants. CA

n of litigation or for trial. ace Alachua General Hospital. Inc. v. Zimmer USA. Inc., 403 So.2d 1087 (Fla. 1st DCA 1981); Fed.R. Civ.Pro. 26(bX3XB); Fla.R.Civ.Pro. 1.280; In re Faro Technologies Securities Litigation, 2008 WL 205318 (M.D. Fla. 2008); Lake Shore Radiator. Inc. v. Radiator Express Warehouse

) in the name of other individuals to conceal those assets from potential judgment creditors. I 16. When civil lawsuits were filed against you by Jane DoeMM., you knew that the lawsuits would likely result in substantial judgments against you if they proceeded to trial. 17. When you filed your suit a

ff'Counterdefendant, JEFFREY EPSTEIN, and requests that PlaintiffiCountenlefendant admit or deny the following facts, in accordance with Rule 1.370, Fla.R.Civ.P.: ADMISSIONS 1. You have acted on a sexual preference for minor females' on multiple occasions over the course of at least the last decade. 2.

Defendant and the U.S. Attorney or State Attorney 1-4 Telephone records 5-6 Videos, photographs of residence 7 Documents relating to Plaintiff Jane Doe 8 Air travel records 10 Documents relating to modeling agencies I 1 Correspondence with other witnesses 14, 15, 16, 17, 19 Social networking do

ation of health care providers telephone numbers used by Epstein and his employees general information based on Florida Standard Interrogatories, Fla.R.Civ.P. Form 2, nos. 7, 10, 12 I, 2, 3, 4, 5, 6, 10, 17 7 8 II, 12 13, 14, 164 These Interrogatories, on their face, do not infringe upon or otherwi

Documents Concerning Your claim for damages in this action. 34. All Documents referred to or relied upon by Plaintiffs to prepare "Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in Action," which was filed in the Federal Action as Docket Entry #279. 35. All Documents referred to

/ Counterclaim Plaintiff Alan Dershowitz ("Dershowitz") requests that Plaintiff / Counterclaim Defendant Bradley J. Edwards ("Edwards"), pursuant to Fla.R.Civ.P. 1.350, produce for inspection and/or copying, at the offices of undersigned counsel, the documents and things listed on Schedule "A" below. GEN