Epstein Secrets

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

o Plaintiff's Motion for Protective Order Against Piecemeal Depositions of Jane Doe No.3, Motion to Consolidate Cases for Purposes of Discovery, and Incorporated Memorandum of Law (hereinafter, the Motion"), with incorporated memorandum of law. In support, Defendant states: I. RESPONSE WITH INCORPORATED MEMORANDUM O

A. Marra on 7/16/08. (ir) (Entered: 07/16/2008) 07/18/2008 25 RESPONSE to Motion re 12 Defendant's MOTION to Stay and Memorandum of Law filed by Jane Doe. Replies due by 7/28/2008. (Attachments: # 1 Exhibit A)(Herman, Jeffrey) (Entered: 07/18/2008) 07/21/2008 26 AFFIDAVIT signed by : Jeffrey M. Her

tion re 9 Plaintiff's MOTION to Compel Clerk to Enter Default Against Defendant, or Alternatively, for an Enlgargement of Time to Serve Process, and Incorporated Memorandum of Law filed by Jeffrey Epstein. Replies due by 6/23/2008. (Attachments: # 1 Affidavit for Richard Bamett)(Goldberger, Jack) (Entered: 06/13/2008)

personal massages. 4. Jane Doe estimates that she returned to Epstein's home approximately 100 times between 2001 and 2003. Epstein masturbated in Jane Doe's presence during all but three of the massages she provided. During additional visits, Epstein tried to engage Jane Doe in more and more sexual beha

icers or employees or their assistants. The Court, drawing upon the See Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law at 19-26. 2 Black. Srebnick. Komspan & Stum 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131. Phone: • Fax: • www.RoyBlack.c