Epstein Secrets

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

interrogatory is "harassing,' "outrageous, offensive and is apparently posed for the purpose of intimidating Plaintiff." See Defendant's Motion to Compel directed to Plaintiff's Answers to Defendant's First Set of Interrogatories, addressing identical discovery issues. Both Defendant's interrogatories

009 Page 1 of 8 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, 08-8081 I, 08-80893, 09-80469, 09-80591, 09-80

MOTION FOR PROTECTIVE ORDER AGAINST SECOND DAY OF DEPOSITION OF PLAINTIFF EXTENDING PAST SEVEN HOURS IN THE AGGREGATE Defendant, JEFFREY EPSTEIN ("Epstein"), submits this Response in Opposition to Plaintiffs, Jane Doe No. 4, Motion for Protective Order Against Second Day of Deposition of Plaintiff Ext

ries sustained as a result of her encounters with Mr. Epstein. 8. There are a myriad of issues to cover with

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

he Court were to grant Jane Doe No. 4's Motion, it would essentially be punishing Epstein for timely proceeding with discovery while his Motions to Compel (DE #s 67 & 68) related to past sexual history were still pending, which 1 Despite Jane Doe No. 4's assertion that "[t]he nature of this case, for d

EW AND APPEAL OF PORTIONS OF THE MAGISTRATE'S ORDER DATED FEBRUARY 4, 2010 (DE 462), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and

HE MAGISTRATE'S ORDER DATED FEBRUARY 4, 2010 (DE 462), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and Appeal of Portions of

250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 [email protected] Counsel for Defendant Jeffrey £stein 80893 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax cassellp@law.

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

othing more than a vague and contentless statement that the materials are "likely to lead to the discovery of other admissible evidence." Motion to Compel at 12 n.3, which is all that plaintiff offers as to Request No. 10. This is particularly so given the reality that parties often take positions or o

Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 JANE DOE NO. 2, Plaintiff, VS, JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON I -------------- Related cases: 08-

4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders (DE 462)

o. 19 Beach State Attorney and the USAO may not want to disclose their files for one reason or another. (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NP A i

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

othing more than a vague and contentless statement that the materials are "likely to lead to the discovery of other admissible evidence." Motion to Compel at 12 n.3, which is all that plaintiff offers as to Request No. 10. This is Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY E

AWARD OF REASONABLE EXPENSES Plaintiffs, JANE DOES 2-7, by and through their undersigned counsel, hereby file this Memorandum in Opposition to Epstein’s Motion to Compel Response to First Request to Produce, Overrule Objections, and for an Award of Reasonable Expenses, and state as follows: I. I

nses, and state as follows: I. Introduction Defendant Epstein served a Request for Production, which includes (

ents, subdivision (c). Defendant has made no such showing in his Motion to Compel to overcome this presumption. Accordingly, Defendant’s Motion to Compel must be denied in its entirety. Defendant also seeks in Request #1 “all tax returns and supporting documentation” dating back to 2002. Plaintif

9 Page 1 of 2 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. STEVEN M. LARIMORE CLERK U.S. DIST

9, 2009, to respond to the Defendant's Motions to Compel, et al. DONE AND ORDERED in Chambers, in Zt ~~L~

Case 9:08-cv-80119-KAM Document 132 Entered on FLSD Docket 06/02/2009 Page 1 of 2 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JUN - 1 2009 STEVEN M. LAfilMORE CLEFlK U.S. DlST. CT. S.D. OF FLA. - W.

ERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of time of until May 6, 2009, to respond to the Defendant's Motions to Compel, et al. DONE AND ~RD ED in Chambers, at West Palm Beach, Palm Beach County, Florida, h• / d f UNG O tis_ ayo ,209. -/ ~ L c;:;;><- ,_,_.