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

ccurate”); Securities and Exchange Commission v. First Jersey Securities, Inc., 843 F.2d 74, 76 (2d Cir. 1988) (rejecting act o

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

n producing records the defendant would not “authenticate the documents as being his own or being accurate”); Securities and Exchange Commission v. First Jersey Securities, Inc., 843 F.2d 74, 76 (2d Cir. 1988) (rejecting act of production argument regarding bank records because “everybody knew that they existed”). C. Th

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502008CA028051)OOO(MB AB L.M. Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF L.M.'s MOTION TO COMPEL ANSWERS TO PLAINTFF'S FIRST REQUEST FOR PRODUCTION Plaintiff L.M. hereby moves this Court for an Or

g. As grounds for the foregoing L.M. states: 1. L.M. has propounded two straightforward requests for production of material previously provided to Epstein by law enforcement authorities in connection with their investigation of Epstein. In response to these requests, Epstein has asserted a Fifth Amend

dvds, cds and ALL other information provided to Defendant Epstein, or his attorneys, in discovery by the Palm Beac

: 502008CA028051)OOO(MB AB L.M. Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF L.M.'s MOTION TO

n producing records the defendant would not "authenticate the documents as being his own or being accurate"); Securities and Exchange Commission v. First Jersey Securities, Inc., 843 F.2d 74, 76 (2d Cir. 1988) (rejecting act of production argument regarding bank records because "everybody knew that they existed"); ]"); Unit