6
Shared Docs
6
Same-Page
18 / 8
Mentions
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-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, 09-804
d 291 (Fla. 3d DCA 1971). Therefore, it is clear in this intentional tort case that punitive damages are an issue. As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and scheme to sexually molest dozens of underage teenage girls.3 Even assuming that the “compelling need” s
tive damages are an issue. As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and scheme
ore tax information may be obtained by a party in discovery.” Bellosa v. Universal Tile Restoration, Inc., 2008 WL 2620735 (S.D. Fla. 2008) (citing Maddow v. Procter & Gamble Co., 107 F.3d 846 (11th Cir. 1997)); accord U.S. v. Certain Real Property, 444 F.Supp. 2d 1258 (S.D.Fla. 2006); Platypus Wear, I
, 2001 WL 34079319 (S.D. Fla. 2001), in which the Court applied the higher standard. These cases do not consider the Eleventh Circuit’s opinion in Maddow, and the federal judges in this District over the past five years since Pendlebury have consistently rejected the “compelling need” standard for pro
DEFENDANT’S MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL Plaintiff, Jane Doe, hereby files this response to defendant Jeffrey Epstein’s Motion for Reconsideration and/or Request for Rule 4 Review and Appeal of Portions of Magistrate’s Order (dkt. #477). The motion should be denie
al of Portions of Magistrate’s Order (dkt. #477). The motion should be denied in its entirety. As the magistrate judge correctly found, defendant Epstein has no valid Fifth Amendment objection to refusing to turn over materials and information already in the Government’s possession. Moreover, the ot
irety. As the magistrate judge correctly found, defendant Epstein has no valid Fifth Amendment objection to refusi
Jane Doe, hereby files this response to defendant Jeffrey Epstein’s Motion for Reconsideration and/or Requ
nte Way, Delray Beach, Fla., 444 F.Supp.2d 1258, 1263 -1264 (S.D.Fla.,2006), he explained that this claim of a higher standard had been rejected by Maddow v. Procter & Gamble Co., Inc., 107 F.3d 846, 853 (11th Cir.1997): Despite the fact that some Courts within the Southern District of Florida have r
JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ________________________________
es are an issue. As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and scheme
tive damages are an issue. As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and scheme
, Inc., 2008 WL 2620735 (S.D. Fla. 2008) (citing Maddow v. Procter & Gamble Co., 107 F.3d 846 (11th Cir.
o not consider the Eleventh Circuit’s opinion in Maddow, and the federal judges in this District over the
JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ________________________________
admission of the genuineness, the existence, and Epstein’s control of such records, and thus presents a re
ages. It appears from evidence in this case that Defendant Epstein earns and funnels income among a labyrinth of bu
0258 (S.D. Fla. 2008) (citing cases relying upon Maddow v. Procter & Gamble Co., 107 F.3d 846 (11th Cir.
A/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. _________________________________
ORDER THIS CAUSE is before the Court on Defendant Epstein’s Motion For Reconsideration and/or Request for R
OMNIBUS ORDER THIS CAUSE is before the Court on Defendant Epstein’s Motion For Reconsideration and/or Request for R
r, has been rejected in the Eleventh Circuit. See Maddow v. Proctor & Gamble Co., Inc., 107 F.3d 846, 853
cted Firms • Appeals Court Says Alabama Can't Execute Intellectually Disabled Inmate • JPMorgan, Ex-Executive Spar In Court Over Responsibility For Epstein BIG PICTURE • New York Times • Wall Street Journal • Washington Post • Financial Times • ABC News • CBS News • NBC News • Fox News EFTA0016
r Jes Staley Blast Jpmorgan's Absent' Claims Over Jeffrey Epstein Ties Back to Top BIG PICTURE New York
icans Banned From Going To Russia • Associated Press: Obama, Colbert Among 500 Americans Banned From Going To Russia • The Hill: Russia Bans Obama, Maddow, Colbert Over Sanctions Russia's Latest Sanctions On U.S. Officials Turn To Trump Enemies • New York Times: Russia's Latest Sanctions On U.S. Offic
Entities connected to both Jeffrey Epstein and Maddow

Prince Andrew
PERSON
John F. Kennedy
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Condoleezza Rice
PERSONJack Goldberger
PERSON
Joe Biden
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATION
Alfredo Rodriguez
PERSON
Bill Clinton
PERSON
Paul Cassell
PERSON
Samantha Power
PERSON
Robert Gates
PERSON
Virginia Giuffre
PERSONRobert D. Critton
PERSON
Barack Obama
PERSONRobert C. Josefsberg
PERSON
Michael Douglas
PERSONMichael J. Pike
PERSON