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,

on 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 suggests that they intend to disclose to these witnesses

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

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 those depositi

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

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 Brown, another former soccer coach of Jane Doe No. 4. 2. Epstein repeatedly postures that Plaintiff is “yet again” seeking to stonewall his discovery e

cutors, FBI agents and lawyers for Maxwell and Epstein's alleged victims." The AP (7/21, Neumeister) reports from New York, "A lawyer for financier Jeffrey Epstein's ex-girlfriend on Tuesday asked a judge presiding over her sex crimes case to impose a gag order on lawyers and others to reduce prejudicial pretria

led a Thursday conference to discuss the possible unsealing of five different sets of documents relating to a defamation lawsuit against Maxwell by Epstein accuser Virginia Giuffre, whom Maxwell had said was lying." Bloomberg adds, "The possible release is coming as Maxwell's lawyer are trying to tamp d

ked girls as young as 14 for her former boyfriend Jeffrey Epstein." US District Judge Loretta Preska in Ne

County, MA, District Attorney Jonathan Blodgett, former Prince George's County, MD, Police Chief Hank Stawinski, Santa Barbara County, CA, Sheriff Bill Brown, Federal Law Enforcement Officers Association National President Larry Cosme, Detroit Police Department Lieutenant Mark Young, Houston Police Chief

/us/articles/2020-07-21/lawyer-for-epsteins-ex-girlfriend-seeks-gag- order-in-case> (7/21, Neumeister) reports from New York, "A lawyer for financier Jeffrey Epstein's ex-girlfriend on Tuesday asked a judge presiding over her sex crimes case to impose a gag order on lawyers and others to reduce prejudicial pretria

uled a Thursday conference to discuss the possible unsealing of five different sets of documents relating to a defamation lawsuit against Maxwell by Epstein accuser Virginia Giuffre, whom Maxwell had said was lying." Bloomberg adds, "The possible release is coming as Maxwell's lawyer are trying to tamp d

ked girls as young as 14 for her former boyfriend Jeffrey Epstein." US District Judge Loretta Preska in Ne

x County, MA, District Attorney Jonathan Blodgett, former Prince George's County, MD, Police Chief Hank Stawinski, Santa Barbara County, CA, Sheriff Bill Brown, Federal Law Enforcement Officers Association National President Larry Cosme, Detroit Police Department Lieutenant Mark Young, Houston Police Chief

omments On Ghislaine Maxwell Case. ABC World News TonightVi (7/21, story 7, 0:20, Muir, 7.14M) reported, "President Trump was asked late today about Jeffrey Epstein's alleged co-conspirator, Ghislaine Maxwell. She pleaded not guilty to sex trafficking charges last week. One of her alleged victims describing her as

led a Thursday conference to discuss the possible unsealing of five different sets of documents relating to a defamation lawsuit against Maxwell by Epstein accuser Virginia Giuffre, whom Maxwell had said was lying." Bloomberg adds, "The possible release is coming as Maxwell's lawyer are trying to tamp d

ked girls as young as 14 for her former boyfriend Jeffrey Epstein." US District Judge Loretta Preska in Ne

County, MA, District Attorney Jonathan Blodgett, former Prince George's County, MD, Police Chief Hank Stawinski, Santa Barbara County, CA, Sheriff Bill Brown, Federal Law Enforcement Officers EFTA00150048 Association National President Larry Cosme, Detroit Police Department Lieutenant Mark Young, Houst

omments On Ghlslalne Maxwell Case. ABC World News TonightVi (7/21, story 7, 0:20, Muir, 7.14M) reported, "President Trump was asked late today about Jeffrey Epstein's alleged co-conspirator, Ghislaine Maxwell. She pleaded not guilty to sex trafficking charges last week. One of her alleged victims describing her as

led a Thursday conference to discuss the possible unsealing of five different sets of documents relating to a defamation lawsuit against Maxwell by Epstein accusers whom Maxwell had said was lying." Bloomberg adds, "The possible release is coming as Maxwell's lawyer are trying to tamp down statements

ked girls as young as 14 for her former boyfriend Jeffrey Epstein." US District Judge Loretta Preska in Ne

County, MA, District Attorney Jonathan Blodgett, former Prince George's County, MD, Police Chief Hank Stawinski, Santa Barbara County, CA, Sheriff Bill Brown, Federal Law Enforcement Officers Association-National-President Larry-Cosme,-Detroit-Police-Department LieutenantMark Young, Houston Police Chief