Epstein Secrets

Australian A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 iagesq(cv,bellsouth.net Counsel for Defendant Jeffi'ey Epstein Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq .. Adam D. Horowitz, Esq.

:/ EPSTEIN'S MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF STORY COWLES AND INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 26(c), Federal Rules of Civil Procedure, moves for a protective order to prohibit the deposition of Story Cowles, and states:

as hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on I July 16, 2008 and has been employed by Mr

esq(cv,bellsouth.net Counsel for Defendant Jeffi'ey Epstein Certificate of Service Jane Doe No. 2 v. Jeffre

pstein Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stua

iscussed the claims asserted against him with Mr. Cowles other than when his attorneys were present or when he was transmitting information between Epstei11 and his attorneys. See Exhibit C. 2 i I ! Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 3 of 8 9. In Octob

ing trial comfs discovery order denying motion for protective order to -prohibit deposhion of defendant's investig-a1:01=s); Quarles & Brady, LLP v. Birdsall, -802 So. 2d - -• - - • 1205, 1206 (Fla. 2d DCA 2002) (quashing order compelling law firm secretary to answer deposition questions regarding her co

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-8109

Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 EPSTEIN'S MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF STORY COWLES AND INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN ("Epstein"),

IV-80119-MARRA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0

as hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on July 16, 2008 and has been employed by Mr. G

hing trial court's discovery order denying motion for protective order to prohibit deposition of defendant's investigators); Quarles & Brady, LLP v. Birdsall, 802 So. 2d 1205, 1206 (Fla. 2d DCA 2002) (quashing order compelling law firm secretary to answer deposition questions regarding her conversations

d. Florida courts are unequivocal in stating that an opposing party can never obtain attorney-client privileged materials. See Quarles & Brady LLP v. Birdsall, 802 So. 2d 1205, 1206 (Fla. 2d DCA 2002) (quashing discovery order and noting “undue hardship is not an exception (to disclosure of privileged mater

unting the allegations: The Joinder Motion then goes on to allege — without any supporting evidence — as follows: One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein’s and well-kn

Q. [Y]ou [are] aware that years before December of 2014, when the CVRA pleading was filed, that your name had come up repeatedly in connection with Jeffrey Epstein’s abuse of minors, correct? . . . A. Let me answer that question. I am aware that never before 2014, end of December, was it ever, ever alleged that I