Epstein Secrets

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ______________ ___;! Related case

ED MOTION TO STRIKE Defendant, JEFFREY EPSTEIN ("Epstein"), submits this Response in Opposition to Plaint

, Jane Doe did not give or receive oral sex from Mr. Epstein, did not engage in anal or vaginal sex with Mr.

,000 in damages in this case, primarily to "hurt Jeffrey Epstein." See 9/20/09 Deposition Transcript of Ja

(also found in Fed. R. Civ. P. 30(d)), Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D.W.Va. 2009) is illustrativ

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

4's deposition. 15. Although the Court waived the seven hour time limit in S.D. Fla. L.R. 26.1 K (also found in Fed. R. Civ. P. 30(d)), Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D.W.Va. 2009) is illustrative and supports Epstein's request for additional time to depose Plaintiffs. In Osborne, a personal i

A/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. _________________________________

allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion hom

hey were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion home. The

that she was deposed for 8 hours. For his part, 1 Defendant Epstein contends in his Response in Opposition that takin

ry that is central to his defense. See Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D. W.Va. 2009)(granting the d

1 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, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469

consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

that she was deposed for 8 hours. For his part, 1 Defendant Epstein contends in his Response in Opposition that takin

allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion ho

he circumstances and result in prejudice to Epstein by denying him the opportunity to obtain discovery that is central to his defense. See Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D. W.Va. 2009)(granting the defendant an additional one day of 7 hours to depose the plaintiff, reasoning that because the plaint