Epstein Secrets

/23/2009 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. I Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80581, 09-80656, 09-80802, 09-8

LAINTIFF JANE DOE NO. 4'S MOTION FOR SANCTIONS AND MOTION FOR PROTECTIVE ORDER, WITH INCORPORATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein, ("Epstein") by and through his undersigned counsel, serves his Response In Opposition to Plaintiff Jane Doe No. 4's Motion for Sanctions and Motion for Prote

porated Memorandum of Law In support, Epstein states: I. Introduction 1. Prior to the above-referenced Plaintiffs Motion (DE 306), the Defendant, Jeffrey Epstein, served his Motion for Sanctions and to Compel Discovery of Jane Doe No. 4 and Memorandum in Support thereof (DE 305). See attached Exhibit "

to make sure that if the cases go forward and if Mr. Epstein defends the case as someone ordinarily would defe

469, 09-80581, 09-80656, 09-80802, 09-81092. I DEFENDANT EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF JANE DOE N

of party being deposed; (8) good faith of party being deposed in asking to exclude other party; and (9) any other factor deemed relevant by court. Mugrage v. Mugrage, 763 A.2d 347, 349-352 (N.J. 2000)(even when it is not appropriate to exclude the other party from the protected party's deposition, a pr

/24/2009 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ---------------'/ Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80581,09-80656,

POSITION TO PLAINTIFF JANE DOE'S (80893) MOTION FOR MOTION FOR PROTECTIVE ORDER, WITH INCORPORATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein, ("Epstein") by and through his undersigned counsel, serves his Response In Opposition to Plaintiff, Jane Doe's Motion for Protective Order (DE 297)(the "Moti

or Protective Order (DE 306). In support, Epstein states: I. Introduction 1. The purpose of Plaintiffs Motion is to, among other things, prevent Jeffrey Epstein from attending the depositions of the Plaintiff in this matter based upon Plaintiff and her lawyers loose interpretation of certain No-Cont

to make sure that if the cases go forward and if Mr. Epstein defends the case as someone ordinarily would defe

1,09-80656,09-80802,09-81092. ---------------'/ DEFENDANT EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF JANE DOE'S

of party being deposed; (8) good faith of party being deposed in asking to exclude other party; and (9) any other factor deemed relevant by court. Mugrage v. Mugrage, 763 A.2d 347, 349-352 (N.J. 2000)(even when it is not appropriate to exclude the other party from the protected party's deposition, a p

0/23/2009 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, V. JEFFREY EPSTEIN, Defendant. I -------------- Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80581, 09-80656,

and serves his Response In Opposition To Plaintiffs' Second Motion For Protective Order (DE 364), With Incorporated Memorandum Of Law. In support, Epstein states: Introduction and Background 1. As this Court is well aware, Plaintiffs continue to prevent discovery. As such, several Motions, Responses

ORE CLERK U.S. DIST. CT. S.D. OF FLA. - W.P.B. DEFENDANT EPSTEIN'S EMERGENCY RESPONSE IN OPPOSITION TO PLAINTIFFS

WITH INCORPORATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein, by and through his undersigned counsel,

o-feed costs, Jeffrey Epstein will not object to same. Epstein simply desires to move these cases forward and complete meaningful discovery. 5. In Mugrage v. Mugrage, 763 A.2d 347, 349-352 (N.J. 2000), the court reasoned that "[a]lthough [the wife was] in fear of [her husband], and [was] in good faith