Epstein Secrets

t 110 Entered on FLSD Docket 05/20/2009 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO.2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ---------~! JANE DOE NO.3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ---------~! JANEDOENO.4, Plaintiff, vs. JEFFREY EPSTEIN

ndant. CASE NO.; 08-CV-80591-MARRA/JOHNSON CASE NO.; 08-CV-80656-MARRA/JOHNSON Defendant, Jeffrey Epstein's Reply To Memorandums In Opposition To Epstein's Motion To Compel Answers To First Set Of Interrogatories And First Request To Produce Directed To Jane Doe Numbers2-7 Defendant, JEFFREY EPSTEIN

-4------- R ob e rt D. Critton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a

CASE NO.; 08-CV-80656-MARRA/JOHNSON Defendant, Jeffrey Epstein's Reply To Memorandums In Opposition To

vents discovery of Plaintiffs' sexual activities deal specifically with employer liability for workplace sexual harassment claims. See M-, Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996)(reasoning in a sexual harassment case, employer was entitled to Plaintiff's sexual history while on-duty but not her

JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ________________________________

September 25, 2009, Defendant Jeffrey Epstein (“Epstein”) filed similar Motions to Compel Independent Med

a Plaintiff’s sexual conduct with men other than Defendant Epstein. Dr. Hall has already received the video interv

ember 16, 2009 and September 25, 2009, Defendant Jeffrey Epstein (“Epstein”) filed similar Motions to Comp

rejected in federal courts. See, e.g., Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996) (granting protect

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 Plaintiffs to Answer First Set of Interrogatories and for an Award of Reasonable Expenses, and state as follows: I. Introducti

nses, and state as follows: I. Introduction Defendant Epstein served an Interrogatory (# 18) seeking to unearth

restriction on discovery to preclude inquiry into areas which will clearly fail to satisfy the balancing test” set forth in Rule 412. See Barta v. City and County of Honolulu, 169 F.R.D. at 135. In Barta, the Court confronted this issue in the context of a discovery motion in a civil case. 169 F.R.D. at 133. A former

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 (

2 is merely an evidentiary rule that should be disregarded in discovery disputes has been routinely rejected in federal courts. See, e.g., Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996) (granting protective order pursuant to Rule 412 to prevent a sexual battery and harassment victim from having to disc