Epstein Secrets

.D. Tenn. 2008). 5. Annexed hereto as Exhibit C is the Supplementary Affidavit of George Rush in this proceeding, sworn to on April 30, 2010. 6. Jane Doe's brief in opposition to Jeffrey Epstein's motion for summary judgment dismissing the federal claims in this action ("Si °pp.') may be found on PACER,

brief in opposition to Jeffrey Epstein's motion for summary judgment dismissing the federal claims in this action ("Si °pp.') may be found on PACER, S.D. Ma. Civil Docket for Jane Doe v. Jeffro Epstein, Case # 9:08-cv-80893-KAM ("Dockerp, ppeP4 EFTA00207294 expressions of confidence in the strength o

.D. Tenn. 2008). 5. Annexed hereto as Exhibit C is the Supplementary Affidavit of George Rush in this proceeding, sworn to on April 30, 2010. 6. Jane Doe's brief in opposition to Jeffrey Epstein's motion for summary judgment dismissing the federal claims in this action ("Si °pp.') may be found on PACER,

brief in opposition to Jeffrey Epstein's motion for summary judgment dismissing the federal claims in this action ("Si °pp.') may be found on PACER, S.D. Ma. Civil Docket for Jane Doe v. Jeffro Epstein, Case # 9:08-cv-80893-KAM ("Dockerp, ppeP4 EFTA00612027 expressions of confidence in the strength o

ury and justice shall be administered without sale, denial or delay. Art. I, §21, Fla. Const.; 10A Fla. Jur. 2d, Constitutional Law, §360. 15. If Jane Doe's name is not disclosed and identified, Mr. Epstein will not be afforded his fundamental right to fairly litigate this dispute and prepare for trial.

ychological and emotional damages" and loss of self-esteem and dignity as referenced above). Cherenfant v. Nationwide Credit, Inc. 2004 WL 5315889 (S.D. Ma. 2004)(order allowing discovery of medical records consistent with Plaintiff's allegations in complaint). This too goes directly to Plaintiffs dama

tted willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 26. Epstein's conduct caused severe emotional distress to Jane Doc. Epstein knew or had

Federal Criminal Action.' In these lawsuits, even before civil discovery begins, under the Initial Disclosures required by Fed. R. Civ. P. 26 and S.D. Ma. Local Rule 26.1, Epstein "must" disclose the identities of all the witnesses he would call in his defense to the Federal Criminal Action (Rule 26(a