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-:....::.. _

m's sexual behavior and/or predisposition in the workplace may perhaps be relevant, non-work place conduct will usually be irrelevant. Cf. Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962- 63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to issue of unwelcomeness of sexual advances at

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

im's sexual behavior and/or predisposition in the workplace may perhaps be relevant, non-work place conduct will usually be irrelevant. Cf. Bums v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962- 63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to issue of unwelcomeness of sexual advances at

EY EPSTEIN, Defendant. CASE NO.: 09-80469-CIV-MARRA-JOHNSON CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT, JEFFREY EPSTEIN'S REPLY TO JANE DOE NO. 101 AND JANE DOE NO. 102'S RESPONSE IN OPPOSITION TO MOTION TO COMPEL AND IDENTIFY JANE DOE NUMBERS 101 AND 102 IN THIRD PART

CASE NO.: 08-CV-8038I-MARRA/JOHNSON EFTA00182748 Case 9:08-cv-80119-KAM Document 152 Entered on FLSD Docket 06/10/2009 Page 2 of 8 Doe 101 v. Epstein Page 2 JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE

OHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 AND 10

v. Epstein Page 4 Defendant, Jeffrey Epstein, ("Mr. Epstein"), by and through his undersigned attorneys, her

ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff,

e 9:08-cv-80119-KAM Document 149 Entered on FLSD Docket 06/09/2009 Page 10 of 13 Doe 101 v. Epstein Page 10 usually be irrelevant. Cf. Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962-63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to issue of unwelcomeness of sexual advances at

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-=-:::-:::-,:::--

m's sexual behavior and/or predisposition in the workplace may perhaps be relevant, non-work place conduct will usually be irrelevant. Cf. Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962- 63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant Case 9:08-cv-80119-KAM Document 67 Entered

iff, JEFFREY EPSTEIN, Defendant. I DEFENDANT, JEFFREY EPSTEIN'S REPLY TO JANE DOE NO. 101 AND JANE DOE NO. 102'8

A/JOHNSON CASE NO.: 08-CV-80381-MARRA/JOHNSON Case 9:08-cv-80119-KAM Document 149 Entered on FLSD Docket 06/09/2009 Page 2 of 13 Doe 101 v. Epstein Page2 Plaintiff, JEFFREY EPSTEIN, Defendant. ___________ / JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. -------------'! JANE DOE

v. Epstein Page4 Defendant, Jeffrey Epstein, ("Mr. Epstein"), by and through his undersigned attorneys, her

age 4 of 13 Doe 101 v. Epstein Page4 Defendant, Jeffrey Epstein, ("Mr. Epstein"), by and through his unde

9:08-cv-80119-KAM Document 149 Entered on FLSD Docket 06/09/2009 Page 10 of 13 Doe 101 v. Epstein Page 10 usually be irrelevant. Cf Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962-63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to issue ofunwelcomeness of sexual advances at w

/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

im's sexual behavior and/or predisposition in the workplace may perhaps be relevant, non-work place conduct will usually be irrelevant. Cf. Bums v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962- 63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant EFTA00221697 Case 9:08-cv-80119-KAM Document

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

im's sexual behavior and/or predisposition in the workplace may perhaps be relevant, non-work place conduct will usually be irrelevant. Cf Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962-63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to issue of unwelcomeness of sexual advances at