Epstein Secrets

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, 09-80802, 09-8109

ERNATIVE RULE 4 APPEAL, WITH INCORPORATED OBJECTIONS AND MOTION FOR PROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Modification and Reconsideration of the Magistrate's Order (DE 555) pursua

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0

e 1400 FL 33401-5012 Counsel for Defendant Jefj•ey Epstein Brad Edwards, Esq. Fanner, Jaffe, Weissing, Edw

upon review of the book or journal by Epstein's criminal lawyer, Jack Goldberger, Esq., it appeam thc "book" or "journal" doca contain the namea of Epatcin's busiftetts-asseeimes-antl-ether--highlr eetifttleyttitt4-eemtitereittilt settstitive-infermatiett-thttt-wett4d he entirely irrelevant to thio act

that the information requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence " chin Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 940. Accordingly, consistent with counsels' agreement noted above, a protective order shou

14 15 16 17 18 19 20 21 22 23 24 25 157 ,; '~ .. \i A O~i 1 Q, And I'm just asking you if you did have '. '· 'tt .} knowledge that Jeffrey Epstein.was having sex will) {_·_ liltle girls either on the plane or al a place that you i were laking him to or from on a daily basis, thal's what t he di

ed them as witnesses to assume ce1iain facts about which they have no knowledge, and he then asks their opinions about certain facts. See Exhibit B ~Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions. 4. There is no information which Mr. Zinoview has relating to the fa

ein and in terms of being able to name 13 not to answer any question that goes to his opinion 13 somebody that you would say you've observed with Jeffrey 14 of someone else's motivation or the truth of facts 14 Epstein and would classify that person as Jeffrey 15 to which he has no knowledge, 15

bit A, he works for Defendant, Jeffrey Epstein ("Mr. Epstein") as a driver and bodyguard. He did not know Mr.

the information requested is neither relevant F to any pending claim or defense nor will it lead to the discovery of admissible evidence," citing Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 13. As illustrated above, the questions are simply not germane to any pending '--.. claim

Case 9:08-cv-80119-KAM Document 560 Entered on FLSD Docket 06/10/2010 Page 1 of 11 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON -------------~/ Related cases: 08-8

ERNATIVE RULE 4 APPEAL, WITH INCORPORATED OBJECTIONS AND MOTION FOR PROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Modification and Reconsideration of the Magistrate's Order (DE 555) pursua

ROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through h

7 of 11 infonnation requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence," citing Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 10. Accordingly, consistent with counsels' agreement noted above, a protective order shou