Epstein Secrets

Case 9:08-cv-80119-KAM Document 247 Entered on FLSD Docket 08/05/2009 Page 1 of 19 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-cv-80119-MARRA/JOHNSON ----------~! JANE DOE NO. 3, CASE NO.

9-80656-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. __________ ___,! Reply To Plaintiffs', Jane Does 2-7, Response In Opposition To Epstein's Motion To Compel And/Or Identify Jane Does In The Style Of This Case And Motion To Identify Jane Doe In Third-Party Subpoenas For Purposes Of Dis

m Of Law (the "Motion to Identify"). In support, Mr. Epstein states as follows: I. Introduction 1. Prior t

amended complaints filed by Jane Does 2-7 against Jeffrey Epstein make allegations of sexual assault and a

ntiffs must show that the requests are unreasonable or burdensome, which they have failed to do in the instant matter); Panola Land Buyers Ass'n v. Shuman, 762 F.2d 1550, 1559 (11 th Cir. 1985); Ward v. Estaleiro Itajai SIA, 541 F.Supp.2d 1344, 1353-54 (S.D. Fla. 2008) (discussing the rules' intended

1 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, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469

0656, 09-80802, 09-81092 ____________________________________/ OMNIBUS ORDER THIS CAUSE is before the Court on the following motions: (1) Defendant Epstein’s Motion to Compel Plaintiff Jane Doe 2 to Respond to Defendant’s First Request to Produce and to Overrule Objections and For an Award of Defendant’s

is before the Court on the following motions: (1) Defendant Epstein’s Motion to Compel Plaintiff Jane Doe 2 to Respon

allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion ho

ee Fed. R. Civ. Case 9:08-cv-80119-KAM Document 377 Entered on FLSD Docket 10/28/2009 Page 4 of 12 5 P. 33(b)(4); Panola Land Buyers Ass’n v. Shuman, 762 F.2d 1550, 1559 (11th Cir. 1985); Rossbach, 128 F.Supp.2d at 1353. Thus, to even merit consideration, “an objection must show specifically how

05 961 9461 305 530-6444 fax FACSIMILE TRANSMISSION COVER SHEET DATE: June 2, 2008 TO: Marie Villafana FAX NUMBER: (561) 820 8777 SUBJECT: Epstein NUMBER OF PAGES, INCLUDING THIS PAGE: 9 Message/Comments: This facsimile contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the us

We come to you in that spirit and respectfully ask for a review of the federal involvement in a quintessentially state matter involving our client, Jeffrey Epstein: While we arc well aware of the rare instances in which a review of this sort is justified, we arc confident that the circumstances at issue warra

DA 99 NE 41" STREET MIAMI, FLORIDA 33132-211 1 Jeffrey H. Sloman First Assistant U.S. Attorney 305 961

us the icon crop of coil lawsuits filed againit Mr. Epstein by Mr. Sloman's roam: law partner. The untweesga

um:twilit, raising our uomurn.4 about the tismrs inappropriate condttet with rotpool to Orb manes. run those avenues have now been shut donna. Mr. Shuman's letter purports to prohibit any further cantata between Mr. lipskirrk defense learn and U.S. Attorney Acosta. and instead requires us to communic

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. _________________________________

exually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion home. The scheme is

allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion ho

R. Civ. P. 33(b)(4); Panola Land Buyers Ass’n v. Shuman, 762 F.2d 1550, 1559 (11th Cir. 1985); Rossbach,

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

te specifically how the objected-to request is unreasonable or otherwise unduly burdensome. See Fed. R. Civ. P.33(b)(4); Panola Land Buyers Ass'n v. Shuman, 762 F.2d 1550, 1559 (11 th Cir. 1985); Rossbach, 128 F.Supp.2d at 1353. Thus, to even merit consideration, "an objection must show specifically ho

Menendez's Bribery Case Reminds Us Why Proving Corruption Is So Hard CRIMINAL INVESTIGATIONS • Ghislaine Maxwell's Lawyer Tell Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Republicans Subpoenaed 15 Years of Hunter Biden Phone Records, Democrats Reveal • Ex-Mar-a-Lago Employee Says He U

on. Lawyers for Maxwell are challenging her December 2021 conviction on multiple grounds, but the only topic at oral arguments was whether the deal Epstein struck in Florida to prevent a federal case against him there also protected Maxwell in New York. Samson said it did. A prosecutor said it didn't. M

islaine Maxwell's Lawyer Tell Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Repub

), Axios (03/12, Falconer), ABC News (03/12, Kim, lbssa), CBS News (03/12, Rosen, Brito, Rinaldi), USA Today (03/12, Jackson), and HuffPost (03/12, Shuman). Capitol Police Defend Actions Surrounding Pipe Bombs Found Jan. 6 EFTA01655836 The Hill (03/12, Irwin) reported that U.S. Capitol Police defend

Menendez's Bribery Case Reminds Us Why Proving Corruption Is So Hard CRIMINAL INVESTIGATIONS • Ghislaine Maxwell's Lawyer Tells Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Republicans Subpoenaed 15 Years of Hunter Biden Phone Records, Democrats Reveal • Ex-Mar-a-Lago Employee Says He U

on. Lawyers for Maxwell are challenging her December 2021 conviction on multiple grounds, but the only topic at oral arguments was whether the deal Epstein struck in Florida to prevent a federal case against him there also protected Maxwell in New York. Samson said it did. A prosecutor said it didn't. M

slaine Maxwell's Lawyer Tells Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Repub

), Axios (03/12, Falconer), ABC News (03/12, Kim, lbssa), CBS News (03/12, Rosen, Brito, Rinaldi), USA Today (03/12, Jackson), and HuffPost (03/12, Shuman). Capitol Police Defend Actions Surrounding Pipe Bombs Found Jan. 6 The Hill (03/12, Irwin) reported that U.S. Capitol Police defended their action

ttached the invite for our event tonight below =o JE has all of the details. Peggy also =ent through

I =ewhouse Mr. & Mrs. Regis Philbin =o:p> Mr. Jason Reitman: director. Work =ncludes JUNO Mr. & Mrs. Morley =afer: on-cam, 60 minutes Mr. =tanley Shuman: Managing Director and a member of the Executive =ommittee of Allen & Co LLC 2 EFTA_R1_01688766 EFTA02540061 Mr. =amp; Mrs. Bob Simon: on-cam, 6