Epstein Secrets

JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ________________________________

September 25, 2009, Defendant Jeffrey Epstein (“Epstein”) filed similar Motions to Compel Independent Med

a Plaintiff’s sexual conduct with men other than Defendant Epstein. Dr. Hall has already received the video interv

ember 16, 2009 and September 25, 2009, Defendant Jeffrey Epstein (“Epstein”) filed similar Motions to Comp

on into their private affairs. , 1996 WL 397563 (D. Kan. 1996) (noting that Rule 412 “is applicable and h

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY E

AWARD OF REASONABLE EXPENSES Plaintiffs, JANE DOES 2-7, by and through their undersigned counsel, hereby file this Memorandum in Opposition to Epstein’s Motion to Compel Plaintiffs to Answer First Set of Interrogatories and for an Award of Reasonable Expenses, and state as follows: I. Introducti

nses, and state as follows: I. Introduction Defendant Epstein served an Interrogatory (# 18) seeking to unearth

- - 5 of discovery under Rule 26, the Court must remain mindful of Rule 412 and its implications); Stalnaker v. Kmart Corp., 1996 WL 397563 (D. Kan. 1996) (noting that Rule 412 “is applicable and has significance in deciding certain discovery motions”). As the above-referenced cases make abunda

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY E

AWARD OF REASONABLE EXPENSES Plaintiffs, JANE DOES 2-7, by and through their undersigned counsel, hereby file this Memorandum in Opposition to Epstein’s Motion to Compel Response to First Request to Produce, Overrule Objections, and for an Award of Reasonable Expenses, and state as follows: I. I

nses, and state as follows: I. Introduction Defendant Epstein served a Request for Production, which includes (

the context of discovery under Rule 26, the Court must remain mindful of Rule 412 and its implications); Stalnaker v. Kmart Corp., 1996 WL 397563 (D. Kan. 1996) (noting that Rule 412 “is applicable and has significance in deciding certain discovery motions”). As the above-referenced cases make abunda

[sexually abuse her] .. . even the most minimal of investigation would have proven conclusively that I could not have had sex with their client on Mr Epstein’s island, in New Mexico or on the airplanes; and that I did not have sex with her in his New York or Palm Beach homes.” DE 282-1 at { 8. On January

, custody or control. 2 Copies of any and all documents reflecting or relating to any and all occasions on which you have been physically present at Jeffrey Epstein’s Ranch in New Mexico including but not limited to your visit to Jeffrey Epstein’s Ranch in New Mexico, as described in paragraph 4 of the sworn Declar

documents evidencing the presence of “members of Mr. Epstein’s legal team”, as described in paragraph 5 of the