Epstein Secrets

cuments are subject to confidentiality provisions, which the federal court recognized and enforced when it permitted disclosure to the attorneys for Jane Doe 1 and Jane Doe 2 and to any other victims and their counsel, provided they not disclose the terms to anyone else. Disclosure violates a condition of t

Clerk theolyil e cad dwa. IS CI INSTRUCTIONS ON THE REVERS( Of THE FOAMS NOTICE: Altorneys MUST Indicate All Re-filed I. (a) PLAINTIFFS -177 re: Jane Poe DEFENDANTS 5-thfeso/ - fttectagi OW 0 D.C. JULY 7, 2008 STEVEN M.LARIMORE CLERK U.S. 01ST. CT. 6.0. Of ILA. - MIAMI (b) Comb &Residence &Pi

ce of this motion to Jeffrey Epstein, through counsel. Jeffrey Epstein's counsel has entered an appearance in several related civil suits, including Jane Doe'. Jeffrey Epstein, United States District Court, Southern District of Florida, Case No.: 08- CIY-80893-MARRA-JOHNSON. Although Epstein's counsel has n

e Addendum thereto. The Court notes the parties were present and represented by counsel. Based upon argument, it is ORDERED AND ADJUDGED that 1. The Motion to Stay is denied. 2. The Clerk of Court shall make the documents available for disclosure at noon on Thursday, July 2, 2009. It is the intent of the Cour

12008 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80069-CIV-MARRA/JOHNSON JANE DOE NO. I, by and through JANE DOE's FATHER as parent and natural guardian, and JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defenda

-1 Entered on FLSD Docket 02/13/2008 Page 4 of 5 Doe's Father, as the custodial parent, is the natural guardian, and the only natural guardian, of Jane Doe. As the natural guardian, Jane Doe's Father may sue on behalf of Jane Doe. See Fed.R.Civ.P. 17(b) (providing that capacity to sue or be sued shall b

ERMELSTEIN, P. A. www.hermanlaw.com - 1 - EFTA00234045 Case 9:08-cv-80069-KAM Document 7-1 Entered on FLSD Docket 02/13/2008 Page 2 of 5 2. The Motion to Stay was not served on all parties as shown on the Motion's Certificate of Service. Only Plaintiff's counsel was served with the Motion. As a result, not

3/2008 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80069-CIV-MARRA/JOHNSON JANE DOE NO. I, by and through JANE DOE's FATHER as parent and natural guardian, and JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defenda

nt 7 Entered on FLSD Docket 02/13/2008 Page 4 of 5 Doe's Father, as the custodial parent, is the natural guardian, and the only natural guardian, of Jane Doe. As the natural guardian, Jane Doe's Father may sue on behalf of Jane Doe. See Fed.R.Civ.P. 17(b) (providing that capacity to sue or be sued shall b

N & MERMELSTEIN, P. A. www.hermanlaw.com - I - EFTA00313588 Case 9:08-cv-80069-KAM Document 7 Entered on FLSD Docket 02/13/2008 Page 2 of 5 2. The Motion to Stay was not served on all parties as shown on the Motion's Certificate of Service. Only Plaintiff's counsel was served with the Motion. As a result, not

cuments are subject to confidentiality provisions, which the federal court recognized and enforced when it permitted disclosure to the attorneys for Jane Doe 1 and Jane Doe 2 and to any other victims and their counsel, provided they not disclose the terms to anyone else. Disclosure violates a condition of t

ce of this motion to Jeffrey Epstein, through counsel. Jeffrey Epstein's counsel has entered an appearance in several related civil suits, including Jane Doe v. Jeffrey Epstein, United States District Court, Southern District of Florida, Case No.: 08- CIY-80893-MARRAJOHNSON. Although Epstein's counsel has

e Addendum thereto. The Court notes the parties were present and represented by counsel. Based upon argument, it is ORDERED AND ADJUDGED that 1. The Motion to Stay is denied. 2. The Clerk of Court shall make the documents available for disclosure at noon on Thursday, July 2, 2009. It is the intent of the Cour

cuments are subject to confidentiality provisions, which the federal court recognized and enforced when it permitted disclosure to the attorneys for Jane Doe 1 and Jane Doe 2 and to any other victims and their counsel, provided they not disclose the terms to anyone else. Disclosure violates a condition of t

e Addendum thereto. The Court notes the parties were present and represented by counsel. Based upon argument, it is ORDERED AND ADJUDGED that 1. The Motion to Stay is denied. 2. The Clerk of Court shall make the documents available for disclosure at noon on Thursday, July 2, 2009. It is the intent of the Cour

n filed an identical Motion to Stay in the case Jane Doe v. Epstein, case no. 08- CIV 80893 MARRA/JOHNSON. Plaintiffs concur in the arguments made by Jane Doe's counsel in that case in opposition to Defendant's Motion. (Case no. 08-CIV 80893, DE 31). The same reasoning and arguments apply in the instant cas

t is therefore difficult to understand how this can be grounds for a stay. Defendant does nothing more than speculate on the intentions of the USAO. The Motion to Stay is therefore, at best, premature. D. Plaintiffs Would Be Prejudiced by a Stay ° The cases discussing the stay issues are premised on a pending cr

in filed an identical Motion to Stay in the case Jane Does. Epstein, case no. 08- CIV 80893 MARRA/JOHNSON. Plaintiffs concur in the arguments made by Jane Doe's counsel in that case in opposition to Defendant's Motion. (Case no. 08-CIV 80893, DE 31). The same reasoning and arguments apply in the instant cas

t is therefore difficult to understand how this can be grounds for a stay. Defendant does nothing more than speculate on the intentions of the USAO. The Motion to Stay is therefore, at best, premature. D. Plaintiffs Would Be Prejudiced by a Stay 'The cases discussing the stay issues are premised on a pending cri

supplied). b. "I am the mother and natural guardian for Jane Doe No. I.. .." (Affidavit of ¶ 1) (emphasis supplied). Exh. "A" to Motion to Stay, Jane Doe's Mother does not have "joint control" or legal custody of Jane Doe, and is not her natural guardian under Florida law. Jane Doe's Mother and Jane Doe

ERMELSTEIN, P. A. - 1 - www.hermanlaw.com EFTA00188252 Case 9:08-cv-80069-KAM Document 7-1 Entered on FLSD Docket 02/13/2008 Page 2 of 5 2. The Motion to Stay was not served on all parties as shown on the Motion's Certificate of Service. Only Plaintiff's counsel was served with the Motion. As a result, not

sanctions pursuant to Rule 30(dX2) aril (3)(A) and (C) (referencing Rule 37(aX5)), Federal Rules of Civil Procedure and compelling the deposition of Jane Doe No. 4 within fifteen (15) days and as grounds therefore would state: 1. On August 16, 2009, the deposition of Jane Doe No. 4 was noticed for Septe

e Addendum thereto. The Court notes the parties were present and represented by counsel. Based upon argument, it is ORDERED AND ADJUDGED that 1. The Motion to Stay is denied. 2. The Clerk of Court shall make the documents available for disclosure at noon on Thursday, July 2, 2009. It is the intent of the Cour

CASE NO.: 08-80069-CIV-MARRA/JOHNSON JANE DOE. NO. 1, by and through JANE DOB's FATHER as parent and natural guardian, and JANE DOB's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFFS' MEMORANDUM OF LAW IN OPPOSITION TO MOTION TO STAY PROCEEDINGS

- 1 - Case No. 08-80736-CV-MARRA P-003653 EFTA00190769 Case 9:08-cv-80069-KAM Document 7-1 Entered on FLSD Docket 02/13/2008 Page 2 of 5 2. The Motion to Stay was not served on all parties as shown on the Motion's Certificate of Service. Only Plaintiffs counsel was served with the Motion. Asa result, notic