Epstein Secrets

/25/2009 Page 1 of 37 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 -------------- DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES, and RESPONSES TO 1st and 2

se protections meaningless in attempting Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 2 of 37 Jane Doe No. 2 v. Epstein Page2 to assert and argue the factual basis for the additional objections and privileges. See part II.A. herein. I. Defendant EPSTEIN has proper

ntains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL." Id, ,I?. "Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas." Id, ,

name in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Request No. 2.

JEFFREY EPSTEIN, Defendant. I -------------- DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWE

n refusing to testify in response to probative evidence offered against them." F.T.C. v. Transnet Wireless Corp., 506 F.Supp.2d 1247, 1252, fn. 4 (S.D.Fla.,2007), citing Mitchell v. United States, 526 U.S. 314, 328, 119 S.Ct. 1307, 143 L.Ed.2d 424 (1999). However, there exists a well recognized except

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

re 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 have a good sense of where else, o

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

re 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 have a good sense of where else, o