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

emain mindful of Rule 412 and its implications); Stalnaker v. Kmart Corp. 12. As the above-referenced case

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

; P.J. Herchenroeder v. John Hopkins Univ. Applied Physical Lab, 171 F.R.D. 179 (D. Mad. 1997); Sanchez v. Zabihi, 166 F.R.D. 500 (D. N.M. 1996); and Stalnaker v. Kmart Corp., 1996 WL 397563 (D. Kan 1996). Plaintiff’s reliance on these cases in support of her position, however, is misplaced in that each of

2009 Page 1 of 9 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 EPSTEIN, Defendant. JANE DOE NO. 4, CASE NO.: 08-CV-8

ant. JANE DOE NO. 7, CASE NO.: 08- 80993-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFFS' MEMORANDUM IN OPPOSITION TO EPSTEIN'S MOTION TO COMPEL ANSWERS TO FIRST SET OF INTERROGATORIES AND FOR AN AWARD OF REASONABLE EXPENSES Plaintiffs, JANE DOES 2-7, by and through their

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

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

ent 93 Entered on FLSD Docket 05'06/2009 Page 5 of 9 of discovery under Rule 26, the Court must remain mindful of Rule 412 and its implications); Stalnaker ICmart Corp. 1996 WL 397563 (D. Kan. 1996) (noting that Rule 412 "is applicable and has significance in deciding certain discovery motions"). As t

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

d on FLSD Docket 05/06/2009 Page 4 of 9 - - 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”). A

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 (

t “[a]lthough the present motion arises in 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”).

From: Jeffrey Epstein [[email protected]] Sent: 9/22/2011 4:48:35 AM To: Sultan Bin Sulayer oo ] Subject: Re: Gps GTX Smart Shoe thanks , great idea ,1i really like

From: Jeffrey Epstein [[email protected]] Sent: 9/22/2011 4:48:35

s with an integrated approach to software, Internet connectivity and customization that lets us focus on our product and service offering," said Eric Stalnaker, VP of Business Development at GTXC. "By working with Enfora, we know the Xplorer® A-GPS Smart Shoe is built on a robust and highly accurate platfor

From: Jeffrey Epstein [[email protected]] Sent: 9/22/2011 10:19:51 AM To: Sultan Bin Sulayer) Subject: Re: Gps GTX Smart Shoe we will have dinnner at 8 ,, you can br

From: Jeffrey Epstein [[email protected]] Sent: 9/22/2011 10:19:51

s with an integrated approach to software, Internet connectivity and customization that lets us focus on our product and service offering," said Eric Stalnaker, VP of Business Development at GTXC. "By working with Enfora, we know the Xplorer® A-GPS Smart Shoe is built on a robust and highly accurate platfor

From: Sent: To: Subject: Jeffrey Epstein [[email protected]] 9/22/2011 10:19:51 AM Sultan Bin Sulayem Re: Gps GTX Smart Shoe we will have dinner at 8 , you can bring your maldives friend

From: Sent: To: Subject: Jeffrey Epstein [[email protected]] 9/22/2011 10:19:51 AM Sul

s with an integrated approach to software, Internet connectivity and customization that lets us focus on our product and service offering," said Eric Stalnaker, VP of Business Development at GTXC. "By working with Enfora, we know the Xplorer® A-GPS Smart Shoe is built on a robust and highly accurate platform