Epstein Secrets

the misconduct demonstrated in the present case - Jeffrey Epstein’s use of discovery as a tactic with the ulterior m

Plaintiffs’ sexual histories with men other than Epstein; and now, by means of a badgering and berating th

O LAW The Magistrate Judge’s decision to grant Defendant Epstein a second day of deposition of Jane Doe No. 4, fo

below. I. Introduction and Summary Defendant Jeffrey Epstein’s demonstrated strategy in defense of the

tion of a party may be supported with cause. See Dunkin Donuts, Inc. v. Mary’s Donuts, Inc., 206 F.R.D. 518, 522 (S.D.

Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 JANE DOE NO. 2, Plaintiff, VS, JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON I -------------- Related cases: 08-

4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders (DE 462)

o. 19 Beach State Attorney and the USAO may not want to disclose their files for one reason or another. (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NP A i

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

pute and (2) a compelling need for the tax returns exists because the information contained therein is not otherwise available. Id. at *2; see also Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001); Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 25 of

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

4 unreasonable or otherwise unduly burdensome.”); Dunkin Donuts, Inc. v. Mary’s Donuts, Inc., 2001 WL 34079319 (S.D. Fl

Case 9:08-cv-80119-KAM Document 488 Entered on FLSD Docket 03/15/2010 Page 1 of 12 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON I 08-80232, 08-08380

F THE MAGISTRATE'S ORDER DATED MARCH 4, 2010 (DE 480), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and Appeal of Portions of

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

pute and (2) a compelling need for the tax returns exists because the information contained therein is not otherwise available. Id. at *2; see also Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001); Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court

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

es are an issue. As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and scheme

tive damages are an issue. As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and scheme

Coffee Co., 2008 WL 2105024 (S.D. Fla. 2005) and Dunkin Donuts, Inc. v. Mary’s Donuts, Inc., 2001 WL 34079319 (S.D. Fl