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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
cause it would only serve purpose of convenience of some witnesses, actions did not share all witnesses and parties were not identical); Borough of Olyphant v. PPL 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 Civi
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
cause it would only serve purpose of convenience of some witnesses, actions did not share all witnesses and parties were not identical); Borough of Olyphant v. PPL 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
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
cause it would only serve purpose of convenience of some witnesses, actions did not share all witnesses and parties were not identical); Borough of Olyphant v. PPL 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
Entities connected to both Jane Doe and Olyphant v. PPL Corporation et al. 153

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONRobert D. Critton
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSONStuart S. Mermelstein
PERSONMermelstein & Horowitz
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATIONLuttier & Coleman
ORGANIZATIONFlorida Rules of Civil
ORGANIZATIONF.R.D. 508
ORGANIZATIONFord Motor Credit Company
ORGANIZATIONKelly v. Kelly
PERSONLeve v. General Motors Corp.
ORGANIZATIONN.D. NY
ORGANIZATION