Epstein Secrets

Case 9:08-cv-80119-KAM Document 262 Entered on FLSD Docket 08/11/2009 Page 1 of 15 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-cv-80119-MARRA/JOHNSON I ----------- JANE DOE NO. 3, Plainti

-'/ Response To Plaintiffs', Jane Does 2-7, Motion for Protective Order (DE 223), With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and through his undersigned attorneys, hereby files his Response In Opposition to Plaintiffs', Jane Does 3 Case 9:08-cv-801

(the "Motion for Protective Order"). In support, Mr. Epstein states as follows: I. Introduction & Argument

n FLSD Docket 08/11/2009 Page 5 of 15 discussed Jeffrey Epstein with her in a public forum, l.e., Jane Do

d whether there was any history of indiscriminate behavior that may have placed them at increased risk .... " Id. It is also important to know about Plaintffs' " ... previous sexual conduct, contact with police or welfare agencies, alcohol or drug use/abuse, voluntary sexual activity, contraceptive use, g

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 EPSTEIN Defendant. CASE NO.: 08-CV-80380-MARRA/JOHNSON

nt. Response To Plaintiffs', Jane Does 2-7, Motion for Protective Order (DE 223), With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and through his undersigned attorneys, hereby files his Response In Opposition to Plaintiffs', Jane Does 3 EFTA00729246 2-7

NO.: 08-cv-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, CASE NO.: 0

(the "Motion for Protective Order"). In support, Mr. Epstein states as follows: L Introduction & Areument 1

alt all traditional investigatory methods which may lead to evidence that may diminish or disprove their claims and/or evidence that may prove that Plaintffs have made inconsistent statements relative to their allegations. 6. As this court is well aware, utilizing investigators prior to and during a la

010 Page 1 of 9 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,

I Response To Plaintifrs, Jane Doe No.: 4, Motion for Protective Order {DE 534), With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and through his undersigned attorneys, hereby files his Response In Opposition to Plaintiffs', Jane Doe's Motion for Protectiv

0 Phone 561/253-0164 Fax (Counsel for Defendant Jeffrey Epstein) Certificate of Service Jane Doe No. 2

whether there was any history of indiscriminate behavior that may have placed them at increased risk .... " Id. It is also important to know about Plaintffs' " ... previous sexual conduct, contact with police or welfare agencies, alcohol or drug use/abuse, voluntary sexual activity, contraceptive use, g