Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ REPLY MEMORANDUM IN SUPPORT OF MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION

mination That Is Insufficient 1. Defendant Cannot Rely on its Blanket Objections to Interrogatories on Fifth Amendment Grounds Defendant Epstein insists that he has not asserted a “blanket privilege” to discovery under the Fifth Amendment, even though he has repeated the identical objection t

o Interrogatories on Fifth Amendment Grounds Defendant Epstein insists that he has not asserted a “blanket privi

or genuinely be expected to be charged with a crime are not subject to Fifth Amendment protection. See Krause v. Rhodes, 390 F.Supp 1070, 1071-72 (N.D. Ohio 1974) (allowing questions to be asked regarding personal backgrounds and experiences excluding the event at issue in the pending criminal indictmen

ristian R. Everdell COHEN & GRESSER LLP Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ted States v. CFW Const. Co., 583 F. Supp. 197 (D.S.C. 1984), of d, 749 F.2d 33 (4'h Cir. 1984) 6 United States v. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 3, 6 United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) 5, 6, 10, 17 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d

7 United States v. Van Thornout, 100 F.3d 590 (8th Cir. 1996) 12 Other Authorities Dienst, J., Valiquette, J., Winter, T., and Fitzpatrick, S. "Jeffrey Epstein Confidante Ghislaine Maxwell Arrested on Sex Abuse Charges." NBC New York. July 3, 2020 15 iii EFTA00028883 --- PAGE BREAK --- Ghislaine Maxw

and powerful. Framing allegations of sexual abuse as "private" protects perpetrators at the expense of victims. The Miami Herald's coverage of Mr. Epstein's and his associates' alleged crimes has nothing to do with consensual sexual preferences and everything to do with the abuse of young girls, whethe

pense of victims. The Miami Herald's coverage of Mr. Epstein's and his associates' alleged crimes has nothing

ependently located any—which supports the sealing of documents based upon alleged evidentiary problems."); Krause v. Rhodes, 535 F. Supp. 338, 354 (N.D. Ohio 1979), aff'd, 671 F.2d 212 (6th Cir. 1982) ("It is not a ground for a protective order as suggested by deponents' counsel, that the depositions cont