Epstein Secrets

es’ 2-7 Motion for Protective Order and Incorporated Memorandum of Law (D.E. 223); Plaintiffs Jane Doe Nos. 2-8’s Motion for Protective Order as to Jeffrey Epstein’s Attendance at Deposition of Plaintiffs, and Incorporated Memorandum of Law (D.E. 292); Affidavit of Dr. Kliman (D.E. 223, Ex. A); Jane Doe No. 4’s M

es Plaintiff Jane Doe No. 4’s Motion for Protective Order, pursuant to S.D.Fla.L.R. 7.1, and states as follows: 1. On April 19, 2010, Defendant Epstein’s counsel advised Plaintiff’s counsel that he was setting dates for additional depositions related to Jane Doe No. 4. The persons to be subpoenaed

and states as follows: 1. On April 19, 2010, Defendant Epstein’s counsel advised Plaintiff’s counsel that he wa

Doe Nos. 2-8’s Motion for Protective Order as to Jeffrey Epstein’s Attendance at Deposition of Plaintiffs,

fe or her daughter making a video. See Exhibit 4, deposition excerpt of Jane Doe No. 4’s mother. 7. Defendant now wants to take the deposition of Rocky Orezzoli, Jane Doe No. 4’s college soccer coach, and Bill Brown, Doe No. 4’s soccer coach in middle and high school. The past conduct of Epstein’s counsel

010 Page 1 of 9 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,

I Response To Plaintifrs, Jane Doe No.: 4, Motion for Protective Order {DE 534), With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and through his undersigned attorneys, hereby files his Response In Opposition to Plaintiffs', Jane Doe's Motion for Protectiv

0 Phone 561/253-0164 Fax (Counsel for Defendant Jeffrey Epstein) Certificate of Service Jane Doe No. 2

discovery and thus preventing Epstein from deposing third parties, including two individuals that were Jane Doe 4's soccer coaches for years (i.e., Rocky Orezzoli and Bill Brown). Limiting such discovery would undoubtedly result in reversible error. Plaintiff claims Epstein is harassing her by way of seeking

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-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, 09-804

ion for Protective Order (“Motion”) is now moot, in part, with regard to the deposition of Rocky Orezzoli, as Mr. Orezzoli was deposed by Defendant Epstein’s counsel on April 30, 2010, while the Motion was pending. However, the Motion remains ripe with regard to the subpoena for deposition of Bill Bro

f Rocky Orezzoli, as Mr. Orezzoli was deposed by Defendant Epstein’s counsel on April 30, 2010, while the Motion was

and states as follows: 1. Plaintiff Jane Doe No. 4’s Motion for Protective Order (“Motion”) is now moot, in part, with regard to the deposition of Rocky Orezzoli, as Mr. Orezzoli was deposed by Defendant Epstein’s counsel on April 30, 2010, while the Motion was pending. However, the Motion remains ripe with