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

their discoverability turns on relevance); MCI Worldcom Network Servs., Inc. v. Von Behren Elec., Inc., No. 1:00CV3311JTC, 2002 WL 32166535, at *4 (N.D.Ga. May 21, 2002) (same) (citing Shearson Lehman Hutton, Inc., 135 F.R.D. at 198). Case 9:08-cv-80119-KAM Document 485 Entered on FLSD Docket 03/1

From: To: Subject: FW: Jeffrey Epstein Date: Tue, 23 Jul 2019 20:46:27 +0000 Let's discuss timing. From: Sent: ues ay, uy , To: Subject: RE: Jeffrey Epstein Yes, I am happy to do wh

n Hi, Our Jeffrey Epstein team here is working on gathering material that may be discoverable in our case or pertinent to an anticipated motion by Epstein for dismissal based on the S.D.Fla. agreement. We assume you had to pull together a lot of discovery for the CVRA litigation, and that you probably

From: To: Subject: FW: Jeffrey Epstein Date: Tue, 23 Jul 2019 20:46:27 +0000 L

probably have a good sense of where else, or with whom else, in the S.D.Fla., we might need to look for pertinent information. The attorne s in the N.D.Ga. who are handling the CVRA litigation said we should check directly with you, and ADAG cleared us to reach out to you directly on this. Would you ha

From: To: Bee: Subject: Jeffrey Epstein Date: Tue, 23 Jul 2019 18:22:13 +0000 Hi, Our Jeffrey Epstein team here is working on gathering material that may be discoverable in our case or

0 Hi, Our Jeffrey Epstein team here is working on gathering material that may be discoverable in our case or pertinent to an anticipated motion by Epstein for dismissal based on the S.D.Fla. agreement. We assume you had to pull together a lot of discovery for the CVRA litigation, and that you probably

From: To: Bee: Subject: Jeffrey Epstein Date: Tue, 23 Jul 2019 18:22:13 +0000 H

probably have a good sense of where else, or with whom else, in the S.D.Fla., we might need to look for pertinent information. The attorneys in the N.D.Ga. who are handling the CVRA litigation said we should check directly with you, and cleared us to reach out to you directly on this. Would you have s