Epstein Secrets

DEFENDANT’S MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL Plaintiff, Jane Doe, hereby files this response to defendant Jeffrey Epstein’s Motion for Reconsideration and/or Request for Rule 4 Review and Appeal of Portions of Magistrate’s Order (dkt. #477). The motion should be denie

al of Portions of Magistrate’s Order (dkt. #477). The motion should be denied in its entirety. As the magistrate judge correctly found, defendant Epstein has no valid Fifth Amendment objection to refusing to turn over materials and information already in the Government’s possession. Moreover, the ot

irety. As the magistrate judge correctly found, defendant Epstein has no valid Fifth Amendment objection to refusi

Jane Doe, hereby files this response to defendant Jeffrey Epstein’s Motion for Reconsideration and/or Requ

of the action, and (2) a compelling need is shown because the information contained therein is not otherwise available.” Dunkin' Donuts, Inc. v. Mary's Donuts, Inc., 2001 WL 34079319 at *2 (S.D.Fla.) (S.D.Fla.,2001) (citing Cooper v. Hallgarten & Co., 34 F.R.D. 482; 483-84 (S.D.N.Y.1964)). Epstein’s tax ret

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

ng 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 37 Doe v. Epstein 08-CV

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

ng 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 can order production

ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE I). The parties and intervenors d

o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that

wise on the subject matter of the action." Milinazzo 1. State Farm Ins. Co., 247 F.R.D. 691, 695-96 (S.D. Fla. 2007) (citing Dunkin' Donuts, Inc... Mary's Donuts, Inc., No. 01-0392, 2001 WL 34079319, at *2 (S.D. Fla. Nov. 1, 2001)). 1. Request No. 1—the FBI File on the Epstein Matter and Indictment Material In th

2015, the Government provided answers to some of the discovery requests. With regard to the discovery requests concerning information about one of Jeffrey Epstein's defense attorneys, Alan Dershowitz, the Government refused to provide any information, asserting that any information about Dershowitz was irrelevan

ent would either produce that information or produce an appropriate privilege log.' The victims believe that the discovery requests regarding one of Epstein's defense attorneys are reasonably calculated to lead to the discovery of admissible evidence, for all the reasons explained in this memorandum. Fo

ery requests concerning information about one of Jeffrey Epstein's defense attorneys, Alan Dershowitz, the

s much broader than relevance for trial purposes." Adelman Boy Scouts of All!" 276 F.R.D. 681, 688 (S.D. Fla. 2011) (citing Dunkin' Donuts, Inc.., Mary's Donuts, Inc., No. 01-0392,2001 WL 34079319, *2 (S.D.Fla. Nov. 1, 2001) (emphases deleted)). This Court has previously explained the "broad" scope of discovery u