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Case 9:08-cv-80119-KAM Document 247 Entered on FLSD Docket 08/05/2009 Page 1 of 19 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-cv-80119-MARRA/JOHNSON ----------~! JANE DOE NO. 3, CASE NO.
9-80656-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. __________ ___,! Reply To Plaintiffs', Jane Does 2-7, Response In Opposition To Epstein's Motion To Compel And/Or Identify Jane Does In The Style Of This Case And Motion To Identify Jane Doe In Third-Party Subpoenas For Purposes Of Dis
m Of Law (the "Motion to Identify"). In support, Mr. Epstein states as follows: I. Introduction 1. Prior t
amended complaints filed by Jane Does 2-7 against Jeffrey Epstein make allegations of sexual assault and a
. See also Fed.R.Civ.Pro. 26; Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978); Dunbar v. U.S., 502 F.2d 206 (5th Cir. 1974); Rossbach v. Rundle, 128 F.Supp.2d 1348, 1354 (S.D. Fla. 200); Fed.R.Civ.Pro 33(b)(4)(Plaintiffs must show that the requests are unreasonable or burdensome, which they
1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ Related cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469
0656, 09-80802, 09-81092 ____________________________________/ OMNIBUS ORDER THIS CAUSE is before the Court on the following motions: (1) Defendant Epstein’s Motion to Compel Plaintiff Jane Doe 2 to Respond to Defendant’s First Request to Produce and to Overrule Objections and For an Award of Defendant’s
is before the Court on the following motions: (1) Defendant Epstein’s Motion to Compel Plaintiff Jane Doe 2 to Respon
allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion ho
the likely benefit. Id. The party resisting discovery has a heavy burden of showing why the requested discovery should not be permitted. Rossbach v. Rundle, 128 F. Supp. 2d 1348, 1354 (S.D. Fla. 2000) (“The onus is on the party resisting discovery to demonstrate specifically how the objected- to informat
NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. _________________________________
exually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion home. The scheme is
allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion ho
ed discovery should not be permitted. Rossbach v. Rundle, 128 F.Supp.2d 1348, 1354 (S.D. Fla. 2000) (“The
al Times • Janet Yellen Says She Expects Ajay Banga to Be Elected World Bank President • JPMorgan Chief Jamie Dimon to Be Interviewed Under Oath in Jeffrey Epstein Lawsuits • Bernie Sanders Accuses Starbucks' Howard Schultz of 'Illegal Union-Busting' ABC News • Russia Suspends Nuclear Treaty Notifications; Ne
mie Dimon to Be Interviewed Under Oath in Jeffrey Epstein Lawsuits • Bernie Sanders Accuses Starbucks' How
Chief Jamie Dimon to Be Interviewed Under Oath in Jeffrey Epstein Lawsuits • Bernie Sanders Accuses Starbu
s coverage of the robbery. Back to Top CYBER DIVISION U.S. to Provide $25 Million to Costa Rica for Cybersecurity The Wall Street Journal (03/29, Rundle) reported that the U.S. will provide cybersecurity support to the government of Costa Rica, officials said, almost a year after a ransomware group l
awsuit against the federal government that begins with a paragraph both familiar and chilling: "For nearly a quarter of a century," Farmer charges, Jeffrey Epstein got away with a "wide-ranging sex trafficking venture" in which she was one of hundreds of victims. And worse, Farmer alleges, the high-profile fina
abused, and sexually exploited victims." The author added that Farmer alleges that she first reported to the FBI that she was sexually assaulted by Epstein and his partner Ghislaine Maxwell in 1996, that she told the agent that Epstein had also committed "multiple serious sex crimes" against other girls
nearly a quarter of a century," Farmer charges, Jeffrey Epstein got away with a "wide-ranging sex traffic
tems." Tech Monitor (06/02, Bairaboina) also reported on the story. U.S. Cyber Agency CISA Faces Stiff Budget Cuts The Wall Street Journal (06/02, Rundle) reported that CISA faces a $495 million funding cut to $2.38 billion in President Trump's proposed budget for fiscal 2026. According to the article
ed a lawsuit against the federal government that begins with a paragraph both familiar and chilling: "For nearly a quarter of a century," charges, Jeffrey Epstein got away with a "wide-ranging sex trafficking venture" in which she was one of hundreds of victims. And worse, alleges, the high-profile financier
ually abused, and sexually exploited victims." The author added that alleges that she first reported to the FBI that she was sexually assaulted by Epstein and his partner Ghislaine Maxwell in 1996, that she told the agent that Epstein had also committed "multiple serious sex crimes" against other girls
: "For nearly a quarter of a century," charges, Jeffrey Epstein got away with a "wide-ranging sex traffic
tems." Tech Monitor (06/02, Bairaboina) also reported on the story. U.S. Cyber Agency CISA Faces Stiff Budget Cuts The Wall Street Journal (06/02, Rundle) reported that CISA faces a $495 million funding cut to $2.38 billion in President Trump's proposed budget for fiscal 2026. According to the article
ry to prove the certainty of their innocence. The Jeffrey MacDonald case discussed previously, is a prime e
passed between the murder and the prosecution and Connolly had a plausible statute of limitations argument on appeal. I was asked by State Attorney Rundle to consult with her appellate lawyers and to prepare them for what they expected would be a grueling oral argument. I agreed and worked with them, an
Microsoft Word - Epstein combined articles.doc
irls. 14. 15.16.17-year-old girls. That should count for something - the difference between prostitution and pedophilia. So, it is baffling that Mr. Epstein, who was indicted last month by a grand jury on one felony count of solicitation of prostitution, has not been charged, as Palm Beach police strenuou
Page: HOUSE_OVERSIGHT_021775 →titution and pedophilia. So, it is baffling that Mr. Epstein, who was indicted last month by a grand jury on o
Page: HOUSE_OVERSIGHT_021775 →the past 13 years that he ought to get off the case. "It looks like a departure from professionalism," Miami-Dade State Attorney Katherine Fernandez Rundle said of Reiter's letter. Following Epstein's indictment, Reiter referred the case to the FBI to determine whether the super-rich, super-connected de
Page: HOUSE_OVERSIGHT_021782 →tution Case By LANDON THOMAS Jr. The bad news arrived by phone last week on Little St. James Island, the palm-fringed Xanadu in the Caribbean where Jeffrey E. Epstein, adviser to billionaires, lives in secluded splendor. Report to the Palm Beach County jail, the caller, Mr. Epstein’s lawyer, said. So over the wee
Page: HOUSE_OVERSIGHT_021786 →d, the palm-fringed Xanadu in the Caribbean where Jeffrey E. Epstein, adviser to billionaires, lives in seclu
Page: HOUSE_OVERSIGHT_021786 →d, the palm-fringed Xanadu in the Caribbean where Jeffrey E. Epstein, adviser to billionaires, lives in seclud
Page: HOUSE_OVERSIGHT_021786 →Entities connected to both Jeffrey Epstein and Rundle

Marc Rich
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
John F. Kennedy
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
United States
LOCATION
Condoleezza Rice
PERSONJack Goldberger
PERSON
Sarah Kellen
PERSON
Joe Biden
PERSON
Prince Charles
PERSONJane Doe
PERSON
Martha Stewart
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Kenneth Marra
PERSON