Epstein Secrets

equest as true, photographing Epstein's genitalia could potentially provide a 'lead or clue' to evidence having a tendency to incriminate. 8. In Jane Doe No. 2 v. Epstein, Case No. 08-CIV-80119 MARRA/JOHNSON, the Court sustained Epstein's Fifth Amendment objections to several interrogatories a

e is not a material fact in controversy pursuant to which the Request could lead to the discovery of relevant and admissible evidence. 17. cite to Harrell v. Hense, 2009 Wt. 409875 (C.D.CaI.) could not better support Epstein's argument herein. Harrell involves a matter where the petitioner was EFTA007

76 EFTA00601652 Appendix B Testimony Cases Last Four Years Year Retained Deliverables Retained by Case 2016 Deposition Report Plaintiff Jane Doe v. Transocean Offshore Deepwater Drilling Inc.; BHP Billiton Petroleum (Deepwater) Ltd.; Schlumberger Technology Corporation; Aramark Services, In

eeting 2017 (ASIST2017). Washington, DC. 27 Oct. - 1 Nov. Salminen, J.O., $engiin, S., Kwak, H., and Jansen, B.J., An, J., Jung, S.G., Vieweg, S., Harrell, F. (2017) Generating Cultural Personas From Social Data: A Perspective of Middle Eastern Users. The Fourth International Symposium on Social Networ

and is ripe for review. The Court has carefully considered the motion and is otherwise fully advised in the premises. On April 14, 2008, Plaintiff Jane Doe No. 4 ("Plaintiff") filed the instant action against Jeffrey Epstein ("Defendant"), alleging claims of sexual assault and intentional infliction of

783 (11th Cir. 1993). To obtain relief under Rule 55(c), the movant must only make a "bare minimum showing" to support her claim for relief. Jones, Harrell, 858 F.2d 667, 669 (11'h Cir. 1988). In evaluating whether a movant has demonstrated "good cause," courts have considered several potential factor

and is ripe for review. The Court has carefully considered the motion and is otherwise fully advised in the premises. On April 14, 2008, Plaintiff Jane Doe No. 5 ("Plaintiff') filed the instant action against Jeffrey Epstein ("Defendant"), alleging claims of sexual assault and intentional infliction of

783 (11th Cir. 1993). To obtain relief under Rule 55(c), the movant must only make a "bare minimum showing" to support her claim for relief. Jones. Harrell, 858 F.2d 667, 669 (11'h Cir. 1988). In evaluating whether a movant has demonstrated "good cause," courts have considered several potential factor

TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defen

red on FLSD Docket 06/12/2009 Page 4 of 19 that the issues of economy, convenience, fairness and comity collectively weigh in favor of remand. See Harrell, 934 F.2d at 205. Comity weighs especially strong, given that the remaining claims are pure state law claims with no connection to federal law. Econ

ould ultimately result in reversible error at any trial. II. Conclusion and Prayer for Relief 22. Epstein requests the following relief: a. That JANE DOE's Motion to Proceed Anonymously be denied; b. That this Court grant Epstein's Motion and that JANE DOE be identified by her legal name in the style

the action to state court. The Court finds that the issues of economy, convenience, fairness and comity collectively weigh in favor of remand. See Harrell, 934 F.2d at 205. Comity weighs especially strong, given that the remaining claims are pure state law claims with no connection to federal law. Econ