Epstein Secrets

sis" for believing discoverable information exists. See In re Southeast Banking Corp, 204 F.3d 1322, 1328 (II' Cir. 2000). Accordingly, counsel for Jane Doe 1 and Jane Doe 2 represent that they have a good faith basis for seeking discovery about sex abuse committed by Alan Dershowitz in concert with Jeffre

e general course of this proceeding. DE 330 at 23 (internal quotation omitted). 8 EFTA00210995 Donahay I. Palm Beach Tours & Transp., Inc,., 242 F.R.D. 685, 687 (S.D. Fla. 2007) (internal quotations omitted). The Federal Rules of Civil Procedure are broadly written and "strongly favor full discovery w

ges that "Epstein committed willful acts of child sexual abuse" on her, which resulted in "mental or sexual injury," and "caused or likely to cause Jane Doe's mental or emotional health to be significantly impaired." 2d Am. Complaint, ¶25. The items sought are clearly relevant to the injuries and damages

reasonably calculated to lead to the discovery of admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Discoverability of such information is governed by Rule 26, Fed.R.Civ.P., pursuant to which the scope of discovery is broad. Dona

eges that "Epstein committed willful acts of child sexual abuse" on her, which resulted in "mental or sexual injury," and "caused or likely to cause Jane Doe's mental or emotional health to be significantly impaired." 2d Am. Complaint, ¶25. The information sought is dearly relevant to the injuries and dama

reasonably calculated to lead to the discovery of admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans.. Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Contrary to Plaintiffs assertion, Rule 412 does not automatically result in a determination that such sexual history and sexual a

GLE COUNT DEFAMATION CASE This case is a simple defamation case. Plaintiff, through her counsel, filed a pleading making certain claims regarding "Jane Doe No. #3" - the Plaintiff- and her alleged 6 EFTA00097401 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 8 of 11 "circumstances." See Com

individuals may have discoverable information does not necessarily entitle a party to depose each such individual." Dixon v. Certainteed Corp., 164 F.R.D. 685, 692 (D.Kan.1996). "The factors relevant to determining whether a party should be entitled to more than ten depositions are now set forth in Fed.R.

this court set forth in Local Rule 2090-1(A). SHAPIRO LAW By: /s/ Peter E. ha it Peter E. Shapiro (FBN Attorneys for Intervenors L.M., E.W., and Jane Doe 10 EFTA00793508 Case 09-34791-RBR Doc 6488 Filed 10/22/18 Page 11 of 165 Attorneys for Jeffrey Epstein SERVICE LIST Bradley J. Edwards FLBN

long as the information is reasonably calculated to lead to the discovery of admissible evidence." Donahay v. Palm Beach Tours & Transp., Inc„ 242 F.R.D. 685, 687 (S.D. Fla. 2007) (internal quotations omitted). The burden is on the party asserting a privilege or other basis for refusing to answer a depos