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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
. As such, consolidation in the instant matter is not warranted in that not all common issues of fact are present and the parties are not identical. Kelly v. Kelly, 911 F.Supp. 66 (N.D. NY 1996Xconsolidation refused because it would only serve purpose of convenience of some witnesses, actions did not share all
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
. As such, consolidation in the instant matter is not warranted in that not all common issues of fact are present and the parties are not identical. Kelly v. Kelly, 911 F.Supp. 66 (N.D. NY 1996)(consolidation refused because it would only serve purpose of convenience of some witnesses, actions did not share al
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
. As such, consolidation in the instant matter is not warranted in that not all common issues of fact are present and the parties are not identical. Kelly v. Kelly, 911 F.Supp. 66 (N.D. NY 1996)(consolidation refused because it would only serve purpose of convenience of some witnesses, actions did not share al
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
. As such, consolidation in the instant matter is not warranted in that not all common issues of fact are present and the parties are not identical. Kelly v. Kelly, 911 F.Supp. 66 (N.D. NY 1996)(consolidation refused because it would only serve purpose of convenience of some witnesses, actions did not share al
Entities connected to both Jane Doe and Kelly v. Kelly

Jeffrey Epstein
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Kenneth Marra
PERSONJack Goldberger
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Alan Dershowitz
PERSONRobert D. Critton
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Adam D. Horowitz
PERSONMichael J. Pike
PERSONStuart S. Mermelstein
PERSONMermelstein & Horowitz
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATIONLuttier & Coleman
ORGANIZATIOND. Critton
PERSONFlorida Rules of Civil
ORGANIZATIONFord Motor Credit Company
ORGANIZATIONF.R.D. 508
ORGANIZATIONN.D. NY
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