Epstein Secrets

Plaintiff Jane Doe, hereby replies to defendant Jeffrey Epstein’s response (DE 339 in consolidated case no. 08-C

el answers to her first request for production. Epstein should be compelled to provide the requested inf

No. 16. Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. Defendant is asser

Plaintiff Jane Doe, hereby replies to defendant Jeffrey Epstein’s response (DE 339 in consolidated case

e not covered by the Fifth Amendment. See, e.g., Rajah v. Mukasey, 544 F.3d 427, 442 (2nd Cir. 2008) (“

A/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. _________________________________

allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion hom

hey were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion home. The

d requests for production that were propounded on Defendant Epstein. Defendant has responded by asserting several ob

subject to Fifth Amendment protection. See, e.g., Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008)(“Jus

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

, considered by the courts to be ‘required records,’ are as a matter of law not subject to Fifth Amendment protection.” Omnibus Order at 12 (citing Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008)); In re Doe, 711 F.2d 1187, 1191 (2d Cir. 1983); In re Doe, 97 F.R.D. 640, 644-45 (S.D.N.Y. 1982)). T