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

under the Federal Rules is to obtain a full and accurate understanding of the true facts in order to obtain a fair and just result. United States v. Proctor & Gamble Co., 356 U.S. 677,682, 78 S.Ct. 983 (1958). 16. Defendant should not have to rely on only those "handpicked" witnesses disclosed by Plaintiff at depo

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

under the Federal Rules is to obtain a full and accurate understanding of the true facts in order to obtain a fair and just result. United States v. Proctor & Gamble Co., 356 U.S. 677, 682, 78 S.Ct. 983 (1958). 16. Defendant should not have to rely on only those "handpicked" witnesses disclosed by Plaintiff at dep

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

nder the Federal Rules is to obtain a full and accurate understanding of the true facts in order to obtain a fair and just result. United States v. Proctor & Gamble Co., 356 U.S. 677,682, 78 S.Ct. 983 (1958). This is evidenced through the intent of rule 26 disclosures. 6. As this court has recognized, Defendant sh

/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW ON EDWARDS' WAIVER OF ATTORNEY-CLIENT AND WORK PRODUCT PROTECTIONS Counter-Defendant Jeffrey Epstein ("Epstein"), submits this M

FENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW ON EDWARDS' WAIVER OF ATTORNEY-CLIENT AND WORK PRODUCT PROTECTIONS Counter-Defendant Jeffrey Epstein ("Epstein"), submits this Memorandum of Law as to the Doctrines of Waiver of Attorney-Client and Work Product protections as claimed by Edwards and at issue

OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

in the substantial equivalent of the materials by other means. A showing of need encompasses a showing of diligence by the party seeking discovery. Proctor & Gamble Co. v. Swilley, 462 So. 2d 1188, 1194 (Fla. 1st DCA 1985). And "No determine whether a moving party will experience undue hardship, courts must balance