Epstein Secrets

Australian A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 iagesq(cv,bellsouth.net Counsel for Defendant Jeffi'ey Epstein Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq .. Adam D. Horowitz, Esq.

:/ EPSTEIN'S MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF STORY COWLES AND INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 26(c), Federal Rules of Civil Procedure, moves for a protective order to prohibit the deposition of Story Cowles, and states:

as hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on I July 16, 2008 and has been employed by Mr

esq(cv,bellsouth.net Counsel for Defendant Jeffi'ey Epstein Certificate of Service Jane Doe No. 2 v. Jeffre

pstein Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stua

iscussed the claims asserted against him with Mr. Cowles other than when his attorneys were present or when he was transmitting information between Epstei11 and his attorneys. See Exhibit C. 2 i I ! Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 3 of 8 9. In Octob

r conversations with hei· supervising partner as the questions invaded the attorney-client privilege). 14. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi

14 15 16 17 18 19 20 21 22 23 24 25 157 ,; '~ .. \i A O~i 1 Q, And I'm just asking you if you did have '. '· 'tt .} knowledge that Jeffrey Epstein.was having sex will) {_·_ liltle girls either on the plane or al a place that you i were laking him to or from on a daily basis, thal's what t he di

ed them as witnesses to assume ce1iain facts about which they have no knowledge, and he then asks their opinions about certain facts. See Exhibit B ~Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions. 4. There is no information which Mr. Zinoview has relating to the fa

ein and in terms of being able to name 13 not to answer any question that goes to his opinion 13 somebody that you would say you've observed with Jeffrey 14 of someone else's motivation or the truth of facts 14 Epstein and would classify that person as Jeffrey 15 to which he has no knowledge, 15

bit A, he works for Defendant, Jeffrey Epstein ("Mr. Epstein") as a driver and bodyguard. He did not know Mr.

d beyond September of 2005. Therefore whatever information Mr. Zinoview may have, postdates that time. 5. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi

010 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, 08-80811, 08-80893, 09-80469, 09-80591,09-80656,

-----'/ EPSTEIN'S RESPONSE IN OPPOSITION TO JANE DOE'S MOTION FOR COURT ORDER RELEASING FBI RECORDS REGARDING EPSTEIN Defendant, JEFFREY EPSTEIN ("Epstein"), submits his Response in Opposition to Plaintiff, Jane Doe's, Motion for Court Order Releasing FBI Records Regarding Jeffrey Epstein ("Motion") (

nowledge regarding others individuals who went to Mr. Epstein's house. This is not a situation where Jane Doe

n for Court Order Releasing FBI Records Regarding Jeffrey Epstein ("Motion") (DE #486) and states: 1. On

opriate and irrelevant and not reasonably calculated to lead to the discovery of admissible evidence." 24. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order,2 "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson

victims"), by and through undersigned counsel, to respond in opposition to Intervenors' Motion for Stay Pending Appeal (DE 193). The intervenors — Jeffrey Epstein and his team of defense lawyers (hereinafter referred to collectively as "Epstein") -- have requested a stay of the Court's order requiring disclos

otion for Stay Pending Appeal (DE 193). The intervenors — Jeffrey Epstein and his team of defense lawyers (hereinafter referred to collectively as "Epstein") -- have requested a stay of the Court's order requiring disclosure of correspondence connected with plea negotiations on behalf of Epstein relatin

Stay Pending Appeal (DE 193). The intervenors — Jeffrey Epstein and his team of defense lawyers (hereinaf

baseless and thus Epstein cannot demonstrate a likelihood of success on the merits and the other requirements for obtaining a stay pending appeal. I. EPSTEIN CANNOT TAKE AN INTERLOCUTORY APPEAL OF THIS COURT'S DISCOVERY ORDER. Epstein has asked the Court for a stay "pending appeal." (DE 193 at I). This r

observes that the intervenors' privilege objections to public release of the correspondence in question were previously rejected by Magistrate Judge Linnea Johnson in a discovery order entered in a parallel civil lawsuit, Jane Doe # 2'. Jeffrey Epstein, Case No. 08-80893-CIV- MARRA." (DE 188 at 3). This Court's

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA 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, 09-80802, 09-8109

Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 EPSTEIN'S MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF STORY COWLES AND INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN ("Epstein"),

IV-80119-MARRA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0

as hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on July 16, 2008 and has been employed by Mr. G

er conversations with her supervising partner as the questions invaded the attorney-client privilege). 14. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. & William

tervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for protective order [DE 160, 161]; intervenor Jeffrey Epstein's opposition to the motion, including motion for protective order [DE 162]; intervenors' notice of supplemental authority in support of asserted comm

er Rule 6(eX3)(AXii) or (iii). 2 EFTA00600055 Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 3 of 11 work-product of Epstein's legal counsel; (2) the correspondence is protected under grand jury secrecy principles codified at Fed. R. Crim. P. 6(e) because its subject matte

District of Florida (USAO/SDFL) and counsel for Jeffrey Epstein to prove the Crime Victims' Rights Act (C

observes that the intervenors' privilege objections to public release of the correspondence in question were previously rejected by Magistrate Judge Linnea Johnson in a discovery order entered in a parallel civil lawsuit, Jane Doe # 2 v. Jeffrey Epstein, Case No. 08- 80893-CIV-MARRA. By order entered January 5,

tervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for protective order [DE 160, 161]; intervenor Jeffrey Epstein's opposition to the motion, including motion for protective order [DE 162]; intervenors' notice of supplemental authority in support of asserted comm

Rule 6(e)(3)(A)(ii) or (iii). 2 EFTA00602808 Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 3 of 11 work-product of Epstein's legal counsel; (2) the correspondence is protected under grand jury secrecy principles codified at Fed. R. Crim. P. 6(e) because its subject matte

District of Florida (USAO/SDFL) and counsel for Jeffrey Epstein to prove the Crime Victims' Rights Act (C

observes that the intervenors' privilege objections to public release of the correspondence in question were previously rejected by Magistrate Judge Linnea Johnson in a discovery order entered in a parallel civil lawsuit, Jane Doe # 2 v. Jeffrey Epstein, Case No. 08- 80893-CIV-MARRA. By order entered January 5,