Epstein Secrets

/23/2009 Page 1 of 13 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 Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80581, 09-80656, 09-80802, 09-8

LAINTIFF JANE DOE NO. 4'S MOTION FOR SANCTIONS AND MOTION FOR PROTECTIVE ORDER, WITH INCORPORATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein, ("Epstein") by and through his undersigned counsel, serves his Response In Opposition to Plaintiff Jane Doe No. 4's Motion for Sanctions and Motion for Prote

porated Memorandum of Law In support, Epstein states: I. Introduction 1. Prior to the above-referenced Plaintiffs Motion (DE 306), the Defendant, Jeffrey Epstein, served his Motion for Sanctions and to Compel Discovery of Jane Doe No. 4 and Memorandum in Support thereof (DE 305). See attached Exhibit "

to make sure that if the cases go forward and if Mr. Epstein defends the case as someone ordinarily would defe

469, 09-80581, 09-80656, 09-80802, 09-81092. I DEFENDANT EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF JANE DOE N

tes v. Benfield, 593 F.2d 815 (8th Cir.1979). Importantly, there are no minor Plaintiffs in this matter or the related matters. All are of age. 5. Moroever, 1 McCormick on Evid., §19 (6th ed.) states, in pertinent part, that: "[flor two centuries, common law judges and lawyers have regarded the opportun

/24/2009 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ---------------'/ Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80581,09-80656,

POSITION TO PLAINTIFF JANE DOE'S (80893) MOTION FOR MOTION FOR PROTECTIVE ORDER, WITH INCORPORATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein, ("Epstein") by and through his undersigned counsel, serves his Response In Opposition to Plaintiff, Jane Doe's Motion for Protective Order (DE 297)(the "Moti

or Protective Order (DE 306). In support, Epstein states: I. Introduction 1. The purpose of Plaintiffs Motion is to, among other things, prevent Jeffrey Epstein from attending the depositions of the Plaintiff in this matter based upon Plaintiff and her lawyers loose interpretation of certain No-Cont

to make sure that if the cases go forward and if Mr. Epstein defends the case as someone ordinarily would defe

1,09-80656,09-80802,09-81092. ---------------'/ DEFENDANT EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF JANE DOE'S

es v. Benfield, 593 F.2d 815 (8th Cir.1979). Importantly, there are no minor Plaintiffs in this matter or the related matters. All are of age. 5. Moroever, I McCormick on Evid., §19 (6th ed.) states, in pertinent part, that: "[f]or two centuries, common law judges and lawyers have regarded the opportun

09-80802, 09-81092 --------------~/ DEFENDANT, JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE,

d on FLSD Docket 10/06/2009 Page 2 of 23 Doe v. Epstein 08-CV80119 Page No. 2 herein. Portions of DE 28

nsuming. Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. Response: Defendan

uant to Florida Statute 796.09 Against Defendant, Jeffrey Epstein". Erie R.Co. v. Tompkins, 58 S.Ct. 817

dence pertaining to the alleged events. (DE 242). Moroever, the requested information could encompass docum