Epstein Secrets

/25/2009 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, V. JEFFREY EPSTEIN, Defendant. I -------------- DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES, and RESPONSES TO 1st and 2

se protections meaningless in attempting Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 2 of 37 Jane Doe No. 2 v. Epstein Page2 to assert and argue the factual basis for the additional objections and privileges. See part II.A. herein. I. Defendant EPSTEIN has proper

ntains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL." Id, ,I?. "Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas." Id, ,

name in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Request No. 2.

JEFFREY EPSTEIN, Defendant. I -------------- DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWE

of primary relevance in this case. In summarizing its holding regarding the application of the Fifth Amendment Privilege to a production request, the Hubbell Court left "no doubt that the constitutional privilege against self incrimination protects" not only "the target of a grand jury investigation from being

, psychologists, psychiatrists, mental health counselors, physicians, hospitals and treatment facilities. No. 9. (Not at issue.)' List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these interrogatories, which were used or intended to be used as sexual aids, s

CT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES, and RESPONSES TO 1st and 2nd PRODUCTION OF DOCUMENTS, AND INCORPORATED MEMO

2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWE

9-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONS

name in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Request No. 2.

of primary relevance in this case. In summarizing its holding regarding the application of the Fifth Amendment Privilege to a production request, the Hubbell Court left "no doubt that the constitutional privilege against self incrimination protects" not only "the target of a grand jury investigation from being

JANE DOE NO. 102, Plaintiff, JEI-HtEY EPSTEIN, Defendant. CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 and 102's MOTION FOR AN ORDER FOR THE PRESERVATION OF EVIDENCE & INCORPORATED MEMORANDUM OF LAW (dated 5/2

CASE NO.: 08-CV-80381-MARRA/JOHNSON EFTA00221589 Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 2 of 11 Doe 101 v. Epstein Page 2 CASE NO.: 08-80994-CIV-MARRA/JOHNSON JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE

ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff,

cket 06/10/2009 Page 3 of 11 Doe 101 v. Epstein Page 3 JANE DOE NO. 101, Plaintiff, JEItREY EPSTEIN Defendant. JANE DOE NO. 102, Plaintiff, JEI-HtEY EPSTEIN, Defendant. CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE

s of primary relevance in this case. In summarizing its holding regarding the application of the Fifth Amendment Privilege to a production request, the Hubbell Court left "no doubt that the constitutional privilege against self incrimination protects" not only "the target of a grand jury investigation from being

2, Plaintiff, JEFFREY EPSTEIN, Defendant. ___________ _)! CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT .JEFFREY EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 and 102's MOTION FOR AN ORDER FOR THE PRESERVATION OF EVIDENCE & INCORPORATED MEMORANDUM OF LAW (dated 5/2

SON I CASE NO.: 08-CV-80381-MARRA/JOHNSON I Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 2 of 11 Doe 101 v. Epstein Page2 JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON ----------~! CASE NO.: 08-80993-CIV-MARRA/JO

0 Phone 561/515-3148 Fax (Counsel for Defendant Jeffrey Epstein) Case 9:08-cv-80119-KAM Document 151

s of primary relevance in this case. In summarizing its holding regarding the application of the Fifth Amendment Privilege to a production request, the Hubbell Court left "no doubt that the constitutional privilege against self incrimination protects" not only "the target of a grand jury investigation from being

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 89 of 91 at vs. Epstein, et al. o.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint self-esteem, loss of dignity, invasion of personal privacy and other damages ass

08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint self-esteem, loss of dignity, invasion of personal privacy and other damages associated with JEFFREY EPSTEIN'S controlling , manipulating, and coercing MI into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical

rsonal privacy and other damages associated with JEFFREY EPSTEIN'S controlling , manipulating, and coercin

s of primary relevance in this case. In summarizing its holding regarding the application of the Fifth Amendment Privilege to a production request, the Hubbell Court left "no doubt that the constitutional privilege against self incrimination protects" not only "the target of a grand jury investigation from being