Epstein Secrets

PLAINT IDE 24, 12/14/091 Defendant JEFFREY EPSTEIN, (EPSTEIN), by and through his attorneys, files his answer and affirmative defenses to Plaintiff JANE DOE No. 8's Amended Complaint, dated December 12, 2009 [DE 24], and states: 1. Without knowledge and deny. 2. As to the allegations in paragraphs 2, D

ing on whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in

N Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / C.M.A., CASE NO.: 08-CV-80811-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. I JANE DOE, CASE NO.: 08-CV-80893-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN et al, EFTA00213024 Defendants. / DOE II, CASE NO.: 09-CV-80469-MARRA/J

bars to suit. I. STANDARD FOR IMPOSING A DISCRETIONARY STAY A. The Defendant Must Show that the Assertion of His Fifth Amendment Privilege Against Self-Incrimination Would Automatically Result in the Entry of Summary Judgment Against Him. "The decision whether or not to stay civil litigation in deference to para

F FLORIDA CASE NO.: 08-CV-80I I 9-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

nt 81 Entered on FLSD Docket 04)20:2009 Page 2 of 11 II. Argument in Reply A. Defendant Has Made a Blanket Assertion of the Privilege Against Self-Incrimination That Is Insufficient 1. Defendant Cannot Rely on its Blanket Objections to Interrogatories on Fifth Amendment Grounds Defendant Epstein insists t

N Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / C.M.A., CASE NO.: 08-CV-80811-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. I JANE DOE, CASE NO.: 08-CV-80893-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN et al, EFTA00222788 Defendants. / DOE II, CASE NO.: 09-CV-80469-MARRA/J

bars to suit. I. STANDARD FOR IMPOSING A DISCRETIONARY STAY A. The Defendant Must Show that the Assertion of His Fifth Amendment Privilege Against Self-Incrimination Would Automatically Result in the Entry of Summary Judgment Against Him. "The decision whether or not to stay civil litigation in deference to para

N Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / C.M.A., CASE NO.: 08-CV-80811-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. I JANE DOE, CASE NO.: 08-CV-80893-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN et al, EFTA00222778 Defendants. / DOE II, CASE NO.: 09-CV-80469-MARRA/J

bars to suit. I. STANDARD FOR IMPOSING A DISCRETIONARY STAY A. The Defendant Must Show that the Assertion of His Fifth Amendment Privilege Against Self-Incrimination Would Automatically Result in the Entry of Summary Judgment Against Him. "The decision whether or not to stay civil litigation in deference to para

N Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / C.M.A., CASE NO.: 08-CV-80811-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. I JANE DOE, CASE NO.: 08-CV-80893-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN et al, EFTA00222798 Defendants. / DOE II, CASE NO.: 09-CV-80469-MARRA/J

bars to suit. I. STANDARD FOR IMPOSING A DISCRETIONARY STAY A. The Defendant Must Show that the Assertion of His Fifth Amendment Privilege Against Self-Incrimination Would Automatically Result in the Entry of Summary Judgment Against Him. "The decision whether or not to stay civil litigation in deference to para

ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

may incrimmate him. U.S.C.A.Const. Amend. 5. [7] Witnesses 410 C=297(1) 410 Witnesses 41011I Examination 410111(D) Privilege of Witness 410 97 Self-Incrimination 410k297(1) k. In General. Most Cited Cases Constitutional guarantee against self- incrimination protects only against forced individual disclo