Epstein Secrets

4/17/2009 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, V. JEFFREY EPSTEIN, Defendant. ___________ ____..cl DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA FOR DEPOSITION O

allowing for the relief requested herein and for such other relief a is court deems just and proper. obert D. Critton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I als

FREY EPSTEIN, Defendant. ___________ ____..cl DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE

2, filed this federal lawsuit against Defendant, Jeffrey Epstein. In another separate matter, a Plaintiff

were not identical); Borough of Olyphant v. PPL Corporation et al., 153 Fed.Appx. 80, 2005 WL 2673489 (C.A.3 (P.A.)); Ford Motor Credit Company v. Chiorazzo, 529 F.Supp.2d 535 (D. N.J. 2008). Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery is not mandatory but

ntiff, JANE DOE 3, by and through their undersigned counsel, and pursuant to Federal Rules of Civil Procedure Rule 33, hereby responds to Defendant, JEFFREY EPSTEIN'S First Set of Interrogatories to Plaintiff as follows: General Oblections 1. Plaintiff objects to Defendant's Interrogatories to the extent that th

CT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO.3. MOTION TO CONSOLIDATE CASES FOR PURPO

2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE

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

were not identical); $orouah of Olvoliant v. PPL Corporation et al. 153 Fed.Appx. 80, 2005 WL 2673489 (C.A.3 (P.A.)); Ford Motor Credit Cornrow v. Chiorazzo, 529 F.Supp.2d 535 (D. N.J. 2008). Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery is not mandatory but

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ PLAINTIFF’S REPLY MEMORANDUM IN SUPPORT OF MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPO

mmon and overlapping facts in these cases, there is no reason why a party witness cannot be questioned in a single sitting on all facts pertinent to Epstein. A protective order is therefore warranted in these cases so that each Plaintiff has her deposition taken only once. Conclusion Based on the f

it would cause delay in one of the cases or if one of the cases is further into discovery than the other case”); see also Ford Motor Credit Co. v. Chiorazzo, 529 F.Supp. 2d 535, 542 (D.N.J. 2008) (denying consolidation of two actions because discovery was nearly complete in one while the other was in it