Epstein Secrets

04/02/2009 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA.JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF. JANE DOE NO. 2. To ANSWER DEFENDANT'S FIRST SET OF INTERROGATORIES AND TO OVERRULE OB

rogatories nos. 10 and 14 are presently resolved. Case 9:08-cv-80119-KAM Document 68 Entered on FLSD Docket 04/02/2009 Page 2 of 9 Doe 2 v. Epstein Page No. 2 Also, Defendant has filed simultaneously with this motion a Motion To Compel directed to certain of Plaintiff's Responses to Defendant'

resses and phone numbers of all males, excluding Mr. Epstein, with whom you have had sexual activity since age

2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF. JANE DOE NO. 2. To

1 [email protected] Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By: __ -1-:....::.. _

dmissible at trial, so long as the discovery is reasonably calculated to lead to the discovery of admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans .. Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Contrary to Plaintiff's assertion, Rule 412 does not automatically result in

2/2009 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, To ANSWER DEFENDANT'S FIRST SET OF INTERROGATORIES AND TO OVERRULE OB

ICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, To ANSWER DEFENDANT'S FIRST SET OF INTERROGATORIES AND TO OVERRULE OBJECTIONS, AND FOR AN AWARD OF D

2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, To

19-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION

resses and phone numbers of all males, excluding Mr. Epstein, with whom you have had sexual activity since age

dmissible at trial, so long as the discovery is reasonably calculated to lead to the discovery of admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans.. Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Contrary to Plaintiffs assertion, Rule 412 does not automatically result in a

bove cause, testified on his oath as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR. SCAROLA: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each of your residence addresses? MR. GOLDBERGER: I think it's beyond the scope. I'm going to object to Fifth

wed to intervene in this action, now respectfully submits this Motion to Compel Jeffrey Epstein to Provide Answers to Deposition Questions. Because Epstein has improperly refused to answer multiple questions at his recent deposition, the motion should be granted. Relevant Factual Background The facts

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

he Agreed Order." DE 6366 at 5 (citing DE 1194). Mr. Epstein improperly refused to answer many questions about

iscoverable, even if not admissible at trial, so long as the information is reasonably calculated to lead to the discovery of admissible evidence." Donahay v. Palm Beach Tours & Transp., Inc„ 242 F.R.D. 685, 687 (S.D. Fla. 2007) (internal quotations omitted). The burden is on the party asserting a privi

4/02/2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA.JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. ----------------'' DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE

ues as to production request no. 14 are presently Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 2 of 12 Doe 2 v. Epstein Page No. 2 resolved. This motion addresses those requests on which the parties were unable to come to an agreement. Also, Defendant has filed sim

JEFFREY EPSTEIN, Defendant. ----------------'' DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO

1 [email protected] Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By: c-=-:::-:::-,:::--

missible at trial, so long as the discovery is reasonably calculated to lead to the discovery of admissible evidence. Rule 26(b)(1 ), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans .. Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Discoverability of such information is governed by Rule 26, Fed.R.Civ.P., purs

age 11 of 50 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80811-MARRA/JOHNSON CAROLYN MARGARET ANDRIANO Plaintiff, V. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, NOTICE OF TAKING DEPOSITION PLEASE TAKE NOTICE that the undersigned attorney will take the deposition duces tecum

or use at trial, or for such other purposes as are permitted under the applicable Statutes of Rules~ Robert D. Critton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing document is being served this day on all counsel of record identified on

6 of 50 8. Presently pending before the Court is Defendant EPSTEIN's Motion to Compel Plaintiff C.M.A. to Respond t

8691 [email protected] Counsel tor Defendant Jeffrey Epstein Searcy Denney Scarola Barnhart & Sh

et 08/05/2009 Page 42 of 50 Case 9:08-cv-80811-KAM Document 54 Entered on FLSD Docket 04/02/2009 Page 3 of 18 C.M.A. v. Epstein, et al. Page3 Donahay v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Discoverability of such information is governed by Rule 26, Fed.R.Civ.P., pursu

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

on, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997)(quoting Broadway and Ninety Sixth Street Realty Co. v. Loew’s Inc., 21 F.R.D. 347, 352 (S.D. N.Y. 1958)); Donahay v. Palm Beach Tours & Transp., Inc., 2007 W.L. 1119206 at *1 (S.D. Fla. 2007). Under Fed. R. Civ. P., 26(b)(1) a court may limit discovery of relevan

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

oew’s Inc., 21 F.R.D. 347, 352 (S.D. N.Y. 1958)); Donahay v. Palm Beach Tours & Transp., Inc., 2007 W.L. 11

/2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE & TO OVERRULE OBJE

ICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE & TO OVERRULE OBJECTIONS. & FOR AN AWARD OF DEFEND

2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO

19-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION

dmissible at trial, so long as the discovery is reasonably calculated to lead to the discovery of admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Discoverability of such information is governed by Rule 26, Fed.R.Civ.P., pursu

, which has been 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

nsolidated 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

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

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

n. 103 F.3d 1007, 1012-13 (C.A. D.C. 1997)(quoting Broadway and Ninety Sixth Street Realty Co. v. Loew's Inc., 21 F.R.D. 347, 352 (S.D. N.Y. 1958)); Donahay v. Palm Beach Tours & Transp., Inc., 2007 W.L. 1119206 at *1 (S.D. Fla. 2007). Accordingly, Plaintiffs' Motion as it relates to Request No. 16 is d

09 Page 1 of 11 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, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656

ent questioning of their past sexual histories in order to prevent the Defendant and a jury from properly analyzing their damages as it pertains to Epstein while, at the same time, blinding the jury from instances in each of the Plaintiffs' lives where psychological, mental, physical and sexual trauma m

0591, 09-80656, 09-80802, 09-81092 I Defendant, Jeffrey Epstein's Reply to Plaintiff, Jane Doe 2-8, Respo

dmissible at trial, so long as the discovery is reasonably calculated to lead to the discovery of admissible evidence. Rule 26(b)(l), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Rule 412 does not automatically result in a determination that such sexual his