Epstein Secrets

JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ________________________________

September 25, 2009, Defendant Jeffrey Epstein (“Epstein”) filed similar Motions to Compel Independent Med

a Plaintiff’s sexual conduct with men other than Defendant Epstein. Dr. Hall has already received the video interv

ember 16, 2009 and September 25, 2009, Defendant Jeffrey Epstein (“Epstein”) filed similar Motions to Comp

routinely rejected in federal courts. See, e.g., Barta v. City and County of Honolulu, 169 F.R.D. 132 (D

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

port of her position that Rule 412 prevents the discovery of Plaintiff’s sexual activities, Plaintiff cites to a string of employment related cases, Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996); Herron v. Eastern Industries, Inc., 2007 WL 2781211 (N.D. Fla. Sept. 19, 2007); Gibbon

2009 Page 1 of 9 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. JANE DOE NO. 4, CASE NO.: 08-CV-8

ant. JANE DOE NO. 7, CASE NO.: 08- 80993-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFFS' MEMORANDUM IN OPPOSITION TO EPSTEIN'S MOTION TO COMPEL ANSWERS TO FIRST SET OF INTERROGATORIES AND FOR AN AWARD OF REASONABLE EXPENSES Plaintiffs, JANE DOES 2-7, by and through their

xpenses, and state as follows: I. Introduction Defendant Epstein served an Interrogatory (# 18) seeking to unearth

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

areas which will clearly fail to satisfy the balancing test" set forth in Rule 412. See Barta I. City and County of Honolulu, 169 F.R.D. at 135. In Barta, the Court confronted this issue in the context of a discovery motion in a civil case. 169 F.R.D. at 133. A former employee brought a sexual harassm

009 Page 1 of 10 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. JANE DOE NO. 4, CASE NO.: 08-CV-8

dant. JANE DOE NO. 7, CASE NO.: 08- 80993-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFFS' MEMORANDUM IN OPPOSITION TO EPSTEIN'S MOTION TO COMPEL RESPONSE TO FIRST REQUEST TO PRODUCE, OVERRULE OBJECTIONS AND FOR AN AWARD OF REASONABLE EXPENSES Plaintiffs, JANE DOES 2-7, by

xpenses, and state as follows: I. Introduction Defendant Epstein served a Request for Production, which includes (

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

nd County of Honolulu, 169 F.R.D. at 135. 5 EFTA00222175 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 6 of 10 In Barta the Court confronted this issue in the context of a discovery motion in a civil case. 169 F.R.D. at 133. A former employee brought a sexual harassme

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 E

AWARD OF REASONABLE EXPENSES Plaintiffs, JANE DOES 2-7, by and through their undersigned counsel, hereby file this Memorandum in Opposition to Epstein’s Motion to Compel Plaintiffs to Answer First Set of Interrogatories and for an Award of Reasonable Expenses, and state as follows: I. Introducti

nses, and state as follows: I. Introduction Defendant Epstein served an Interrogatory (# 18) seeking to unearth

at Rule 412 is merely an evidentiary rule that should be disregarded in discovery disputes has been routinely rejected in federal courts. See, e.g., Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996) (granting protective order pursuant to Rule 412 to prevent a sexual battery and haras

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 E

AWARD OF REASONABLE EXPENSES Plaintiffs, JANE DOES 2-7, by and through their undersigned counsel, hereby file this Memorandum in Opposition to Epstein’s Motion to Compel Response to First Request to Produce, Overrule Objections, and for an Award of Reasonable Expenses, and state as follows: I. I

nses, and state as follows: I. Introduction Defendant Epstein served a Request for Production, which includes (

at Rule 412 is merely an evidentiary rule that should be disregarded in discovery disputes has been routinely rejected in federal courts. See, e.g., Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996) (granting protective order pursuant to Rule 412 to prevent a sexual battery and haras