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CASE NO: 502008CA037319XXXXMB AB Plaintiff, vs. JEFFREY EPSTEIN, Defendants. PLAINTIFF'S NOTICE OF SERVING SUPPLEMENTAL ANSWERS TO DEFENDANT JEFFREY EPSTEIN'S FIRST SET OF INTERROGATORIES DATED DECEMBER 18, 2008 COMES NOW, Plaintiff B.B., by and through her undersigned counsel, pursuant to Florida Rules
TICE COUNSEL Re: B.B. v. Jeffrey Epstein, et al. Case No. 502008CA037319XXXX MBAB 1/26/10, 8:10 a.m. - 30-minute Special Set Hearing on Defendant Epstein's Motion for Sanctions against Spencer Kuvin, Esq. and Alternative Motion to Identify Dear Judge Hafele: With reference to the above-mentioned 30
Supplemental Response to Interrogatory number 15). The time described above in my supplemental response to interrogatory number 15 is the only • r. Epstein's home. I do not know ome address, but at the time Of the node f descrihed shove her mo her lived in the Page 4 of 5 EFTA00599175 •Simme le .
/10, 8:10 a.m. - 30-minute Special Set Hearing on Defendant Epstein's Motion for Sanctions against Spencer Kuvin, Es
A. ' BERNARD A. LEBEDEKER MARK T. LUTTIER. PA. JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER MCNAMARA RUDA
gages in conduct that is malicious, oppressive, or committed with such gross negligence amounting to wanton disregard for the rights of others. See W.R. Grace & Company v. Waters, 638 So. 2d 502 (Fla. 1994). 10. Before a Plaintiff may assert a claim for punitive damages, the trial court must determine that there
5 mentions1 same-page
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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
l conference ... or when it becomes apparent that punitive damages can be awarded." Id. at *5. Since bifurcation is required in the instant matter, W.R. Grace & Company v. Waters, 638 So.2d 502 (Fla. 1994), it is reasonable and consistent with the applicable law, that any tax returns not be produced until such time
5 mentions1 same-page
Page ?Same page
ent 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARR A/JOHNSON Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,
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 NPA is
n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular
conference. . . or when it becomes apparent that punitive damages can be awarded." Id. at *5. Since bifurcation is required in the instant matter, W.R. Grace & Company v. Waters, 638 So.2d 502 (Fla. 1994), it is reasonable and consistent with the applicable law, that any tax returns not be produced until such time
Sponsored
Mutual Connections (69)
Entities connected to both Jeffrey Epstein and W.R. Grace & Company
George W. Bush
PERSON5,075 w/ Jeffrey·2 w/ W.R.
Bradley Edwards
PERSON4,821 w/ Jeffrey·2 w/ W.R.
United States
LOCATION4,786 w/ Jeffrey·2 w/ W.R.
Harry Reid
PERSON4,188 w/ Jeffrey·2 w/ W.R.
JG
Jack Goldberger
PERSON3,877 w/ Jeffrey·3 w/ W.R.
JD
Jane Doe
PERSON3,169 w/ Jeffrey·2 w/ W.R.
MF
Maria Farmer
PERSON2,740 w/ Jeffrey·2 w/ W.R.
Paul Cassell
PERSON2,045 w/ Jeffrey·2 w/ W.R.
Justin Trudeau
PERSON2,009 w/ Jeffrey·2 w/ W.R.
Jay Lefkowitz
PERSON1,517 w/ Jeffrey·2 w/ W.R.
Bradley Cooper
PERSON1,436 w/ Jeffrey·2 w/ W.R.
SR
Scott Rothstein
PERSON1,321 w/ Jeffrey·2 w/ W.R.
RC
Robert D. Critton
PERSON1,155 w/ Jeffrey·2 w/ W.R.
Harvey Weinstein
PERSON1,137 w/ Jeffrey·2 w/ W.R.
RJ
Robert C. Josefsberg
PERSON891 w/ Jeffrey·2 w/ W.R.
MP
Michael J. Pike
PERSON771 w/ Jeffrey·3 w/ W.R.
Adam D. Horowitz
PERSON670 w/ Jeffrey·2 w/ W.R.
Salt Lake City
LOCATION658 w/ Jeffrey·2 w/ W.R.
KE
Katherine W. Ezell
PERSON585 w/ Jeffrey·2 w/ W.R.
SK
Spencer Kuvin
PERSON498 w/ Jeffrey·3 w/ W.R.