Epstein Secrets

A/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. _________________________________

allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion hom

hey were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion home. The

d requests for production that were propounded on Defendant Epstein. Defendant has responded by asserting several ob

ubbell, 530 U.S. 27, 44 (2000); United States v. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006). Thus, whil

Fisher, 425 U.S. at 410; Hubbell, 530 U.S. at 44; Ponds, 454 F.3d at 325 (D.C. Case 9:08-cv-80119-KAM D

Plaintiff Jane Doe, hereby replies to defendant Jeffrey Epstein’s response (DE 339 in consolidated case no. 08-C

el answers to her first request for production. Epstein should be compelled to provide the requested inf

No. 16. Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. Defendant is asser

Plaintiff Jane Doe, hereby replies to defendant Jeffrey Epstein’s response (DE 339 in consolidated case

very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecut

DEFENDANT’S MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL Plaintiff, Jane Doe, hereby files this response to defendant Jeffrey Epstein’s Motion for Reconsideration and/or Request for Rule 4 Review and Appeal of Portions of Magistrate’s Order (dkt. #477). The motion should be denie

al of Portions of Magistrate’s Order (dkt. #477). The motion should be denied in its entirety. As the magistrate judge correctly found, defendant Epstein has no valid Fifth Amendment objection to refusing to turn over materials and information already in the Government’s possession. Moreover, the ot

irety. As the magistrate judge correctly found, defendant Epstein has no valid Fifth Amendment objection to refusi

Jane Doe, hereby files this response to defendant Jeffrey Epstein’s Motion for Reconsideration and/or Requ

2004). The D.C. Circuit has recently refused to extend the act of production doctrine on facts very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecutors sought information about possible crimes committed by a defense attorney in the course of repre

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

consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion ho

is known to the government or is a foregone conclusion. Fisher, 425 U.S. at 410; United States v. Hubbell, 530 U.S. 27, 44 (2000); United States v. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006). Thus, while the Fifth Amendment covers situations where the act of producing documents has “communicative aspe

y Persons Holding a Legal or Beneficial Interest Reiasng to the Consumer Comprehensive Report Comprehensive Report Date: 03/18/10 Reference Code: Epstein Report processed by: Burman, Coition, LOW & Coleman 515 North %glee Drive West Palm Beach, FL 33401-4349 Phone Subject Information (Beat Infor

ent Residents at Addres►: GRETCHEN BEICAH CERNY PREMUROSO A MY SIDMIARTH DINESHCHANDRA SHAH bid 1999 - Feb 2010) Current Residents at Address: JEFFREY D MCNEILLY LAURA MCNElL PREMUROSO A RAY CHRISTOPHER MICHAEL MCNEILL CHRIS S PREMUROSO ED ALEXANDER MCNEILL NEILL I. Jan 2000 2004) PREMUROSO

B: 51xx/1975 Age: 34 592-81-xxxx issued In Florida between 8/1/1998 and 12/2/1996 TAMARA VILLAVICENCIO DOB: 86301975 Age: 94 592-61-xxxx issued in Ponds between 8/1/1998 and 12/2/1996 Active Address(es): 410 May 2002 - Nov 2009) 964431.6568 VILLAVICENCIO FREDDY 3/18/2010 EFTA00729173 Comprehen