Epstein Secrets

J.'s have been filed against Epstein in the last three years. Epstein has settled all of the cases. Among those cases was a federal lawsuit filed by Jane Doe in this court, styled as Jane Doe v. Epstein, 9:08-cv-80893. M.J.'s legal counsel also handled Jane Doe's case against Epstein. 15. While working

g those cases was a federal lawsuit filed by Jane Doe in this court, styled as Jane Doe v. Epstein, 9:08-cv-80893. M.J.'s legal counsel also handled Jane Doe's case against Epstein. 15. While working on that case and others like it, Edwards learned through deposition that Ghislaine Maxwell was involved in

e court must then "weigh and determine (the) disputed issues of facts on a Rule 12(b)(5) motion." Cranford v. United States, 359 F.Supp.2d 981, 984 (E.D. Cal. 2005). An evidentiary hearing is the proper vehicle for resolving this particular factual dispute. See Blair v. City of Worcester, 522 F.3d 105, 1

investigation against the Defendant, Jeffrey Epstein. 7. During the criminal investigation, and up and through this point in time, the Plaintiff, Jane Doe's identity has been sealed, as all parties recognize the highly sensitive subject matter of the charges and the need to protect the privacy interest o

EN M. LARIM0RE CLERK U.S. GIST. CT. S.D. FLA. • MIAMI highly sensitive nature — i.e., allegations involving sexual abuse of a minor. Additionany, Jane Doe's name was kept anonymous in the Federal Court criminal case and all documents containing her name were redacted by the United States Government and D

ases, with minimal discussion. Roe v. Wade, 410 U.S. 113, 120-121, 93 S.Ct. 705 (1973); See also, E.E.O.C. v. ABM Industries, Inc., 249 F.R.D. 588 (E.D. Cal. 2008). Likewise, pseudonym filing is typically accepted by the courts in other cases where the nature of the pleading unveils highly sensitive inf

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

purely procedural in nature and does not create a federal physician-patient or hospital-patient privilege." Allen v. Woodford 2007 WL 309485 *I I (E.D. Cal. 2007). Under HIPAA, health care information may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing

ersion of 18 U.S.C. §2255, effective 1999 to Jul. 26, 2006, the period of time during which EPSTEIN's alleged conduct occurred, applies to Plaintiff JANE DOE's claim brought pursuant to §2255 in Count II of the First Amended Complaint [D.E. 38]; (2) the version of 18 U.S.C. § 2255 in effect when the predic

CV-80893-Marra-Johnson Page 7 Cal. Aug. 19, 2009); U.S. v. Ferenci, 2009 WL 2579102, fn. 1 (ED. Cal. Aug. 19, 2009); U.S. 2009 WL 2567831, fn. 1 (E.D. Cal. Aug. 18, 2009); U.S. v. Zane, 2009 WL 2567832, al (ED. Cal. Aug. 18 2009). In each of these cases, the referenced footnote states — Prior to July

ing these protections meaningless in attempting EFTA00222075 Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 2 of 37 Jane Doe No. 2 v. Epstein Page 2 to assert and argue the factual basis for the additional objections and privileges. See part ILA. herein. I. Defendant E

(Health Insurance Portability and Accountability Act) objection, as noted in the case cited in Plaintiffs motion Allen v. Woodford, 2007 WL 309485 (E.D. Cal. 2007), (p. 9), HIPPA institutes procedural safeguards to protect the privacy of an individual's medical information and history. In the context of

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

purely procedural in nature and does not create a federal physician-patient or hospital-patient privilege." Allen v. Woodford 2007 WL 309485 *I I (E.D. Cal. 2007). Under HIPAA, health care information may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing