Epstein Secrets

48/51 Date. 5/29/200812.09.. M 312 , 2 AFFIDAVIt OFSCRV10E Ref. 60.154 A I Sui Circuit Coin County index/Case., k72008 CA 00606_JFIling Pete June Doe, by and through Jane Doe's Mother as parent and natural guardian - --- . . —.-.. — • 1 )1;. - rawer Jeffrey Epstein, all= -- - - ....._€"4-1,.

09.. M 312 , 2 AFFIDAVIt OFSCRV10E Ref. 60.154 A I Sui Circuit Coin County index/Case., k72008 CA 00606_JFIling Pete June Doe, by and through Jane Doe's Mother as parent and natural guardian - --- . . —.-.. — • 1 )1;. - rawer Jeffrey Epstein, all= -- - - ....._€"4-1,. (ro c?: Sug0q1CottlIty, S

s upon Defendant, Jeffrey Epstein, and as grounds therefore states as follows: 1. A complaint n this action was filed on March 6, 2008. Pursuant to Florida Rules of Civil Procedure 1.070(j), Plaintiff has until July 6, 2008 to serve this Defendant. 2. The Complaint includes claims for Sexual Assault, Civil Conspiracy

se No. 08-cv- 80736-MARRA/JOHNSON (S.D. Fla.) (the "Federal Action"). 6. According to the "Emergency Petition" filed in the Federal Action (DE #1), Jane Doe #1 is an adult who allegedly "was a victim of federal crimes committed by Jeffrey Epstein" ("Epstein") within the jurisdiction of the Southern Distr

GAINST PLAINTIFFS/COUNTERCLAIM DEFENDANTS EDWARDS AND CASSELL Defendant and Counterclaim Plaintiff, Alan M. Dershowitz ("Dershowitz"), pursuant to Florida Rules of Civil Procedure 1.170(a), 1.170(e), 1.190(a) and 1.190(f) and Florida Statute § 768.72, hereby respectfully moves this Court for entry of an order grantin

the federal rules while at the same time asking this court to limit or prevent her deposition testimony as a witness in the instant matter or other Jane Doe matters where she has been identified as a witness. It is well settled that a Defendant may take the deposition of a party and/or a witness before

Comoration et al., 153 Fed.Appx. 80, 2005 WL 2673489 (CA.3 (P.A.)); Ford Motor Credit Company v. Chiorazzo 529 F.Supp.2d 535 (D. N.J. 2008). Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery is not mandatory but that decision remains within the sound discretion of the court. I

OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, Intervenors.' ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Bea

24 236 So.2d 189 (Fla. 4th DCA 1970) Turner Construction Co. v. ENF Contractors, Inc., 24 939 So.2d 1108 (Fla. 3d DCA 2003) RULES Rule 1.440, Florida Rules of Civil Procedure 17, 18, 19, 20, 21 Rule 1.500(a), Florida Rules of Civil Procedure 15, 19 iv EFTA00808518 THE WRIT OF MANDAMUS "Mandamus is a narro

e Number: Our Client: Dear Mr. April 15, 2009 Jane Doe II - CA 020614 Jeffrey Epstein Sandra W. Hughe

nts. DEFENDANT. JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER The Defendant, JEFFREY EPSTEIN, by and through the undersigned attorney pursuant to Florida Rules of Civil Procedure 1.280 ( c) files the following Motion for Protective Order and as grounds therefore states as follows: 1. The undersigned has been retai

v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE ORDER AND TO_QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO.3, MOTION TO CONSOLIDATE CASES FOR PURPOSES OF DISCOVERY, AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT Defendant, JEFFREY EPSTEIN, by and thro

Corporation et al. 153 Fed.Appx. 80, 2005 WL 2673489 (C.A.3 (P.A.)); Ford Motor Credit Company v. Chiorazzo 529 F.Supp.2d 535 (D. N.J. 2008). Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery is not mandatory but that decision remains within the sound discretion of the court. I

v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE ORDER AND TO_QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO.3, MOTION TO CONSOLIDATE CASES FOR PURPOSES OF DISCOVERY, AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT Defendant, JEFFREY EPSTEIN, by and thro

Corporation et al. 153 Fed.Appx. 80, 2005 WL 2673489 (C.A.3 (P.A.)); Ford Motor Credit Company v. Chiorazzo 529 F.Supp.2d 535 (D. N.J. 2008). Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery is not mandatory but that decision remains within the sound discretion of the court. I

t al. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 EFTA00606748 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. CASE NO. 08-CV-80893-CIV-MARFtNJOHNSON Related Cases: 08-80119, 08-80232, 08-80380, 08-8038

relative nor employee of such attorney or counsel, and who is not financially interested in the action. Said deposition will be taken pursuant to Florida Rules of Civil Procedure in such cases provided. Said oral examination will continue from hour to hour and from day to day until completed. EFTA00606747 CERTIC

v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO.3, MOTION TO CONSOLIDATE CASES FOR PURPOSES OF DISCOVERY. AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT Defendant, JEFFREY EPSTEIN, by and thro

rporation et al., 153 Fed.Appx. 80, 2005 WL 2673489 (C.A.3 (P.A.)); Ford Motor Credit Company v. Chiorazzo, 529 F.Supp.2d 535 (D. N.J. 2008). Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery is not mandatory but that decision remains within the sound discretion of the court. I