Epstein Secrets

MOTION TO TAKE THE INTERVENORS' DEPOSITIONS AND TO COMPEL THEIR MENTAL EXAMINATIONS Jeffrey Epstein ("Epstein") replies to the Intervenors, IM and Jane Doe's Response (D.E. 6446) to Epstein's Motion to Take the Intervenors' Depositions and to Compel their Mental Examinations (Epstein's "Motion") (D.E. 64

l states in controversy. See D.E. 6432; see also, e.g., Reaves v. Wayne Automatic Fire Sprinklers, Inc., No. 2:11-cv-00049-CEH-SPC, 2011 WL 4837253 (M. Fla. Oct. 12, 2011). As such, Rule 35 entitles Epstein to the Intervenors' independent mental examinations. The Intervenors suggest that Rule 35 does no

el for Petitioner 1555 Palm Beach Lakes Blvd. Suite 301 West Palm Beach, Florida 33401 'As set forth in Epstein's Petition, non-parties E.W. and Jane Doe have sought to intervene below on a limited and unrelated issue. As such, they are not parties in this certiorari proceeding, and Edwards has impro

2d 733, 737 (Fla. 3d DCA 1981) (emphasis added). See also Estate of Carrillo v. Fed. Deposit Ins. Corp., No. 11-22668-CIV, 2012 WL 13013081, at *1 (M. Fla. Apr. 25, 2012) ("Bifurcation is the exception, not the rule, and the party seeking bifurcation shoulders the heavy burden of establishing that bifu

that Rush had waived sa applicable reporter's privilege by disclosing brief portions of the Epstein interview to third parties (Balin Aff. Ex. K (Jane Doe's Response in Opposition to Motion of Daily News, to Quash Subpoena), at 6-13) — the same exact waiver argument he makes here. The federal District

,25 29 28,29 In re Zallie, 2009 WL 2844429 (Sup. Ct. M. Co. Aug. 13, 2009) 12, 15, 21 Johnson Law Group v. limadebt USA, LLC, 2010 WL 2035284 (M. Fla. May 24, 2010) 18 Kirkland & Ellis v. Chadl e & Parke LLP, 176 Misc.2d 73, 670 .2d 753 (Sup. Ct. Co. 1998) 12 Kooper v. Kooper, 74 El3d 6, 901