Epstein Secrets

-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL ED RICCI SPECIAL CONSUMER JUSTICE COUNSEL Dear Judge Hafele: Enclosed, please find Jeffrey Epstein's Response in Opposition to ll's Motion for Inspection and to Compel Discovery, which are set for hearing before Your Honor on December 14, 2009 at 8

E FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XWMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR INSPECTION AND TO COMPEL DISCOVERY AND MOTION FOR PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LAW Defen

in from disclosing the identity of any person who has knowledge or are in possession of physical evidence (i.e. photographs, EFTA00723281 B,B. v, Eosteiq Case No. 502008CA03 XMB AB Epstein's Objections to Request and Motion for Protective Order Page 10 of 22 videos, written statements, etc.) pert

P. 1.280(c), and states: I. Introduction 1. Mr. Epstein's deposition was set for September 2, 2009, and M

Motion to Compel as to certain requests to which Defendant Epstein was asserting a Fifth Amendment privilege. By th

P.A. BERNARD LESEDEKER. MARK T. LL/TTIER. P.A. JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER. MCNAMARA RUDA

ppear to infringe upon or otherwise implicate Epstein's rights under the Fifth Amendment, based on the particularized showing made by Epstein in his Response Memorandum, the 8 EFTA00723243 Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 9 of 22 facts alleged in the Complaints, and the

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 0

, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 PLAINTIFF JANE DOE'S EMERGENCY MOTION TO HAVE EPSTEIN HELD IN CONTEMPT FOR FAILING TO PRODUCE STATE DISCOVERY AND CORRESPONDENCE AND FOR PRODUCING ONLY REDACTED CORRESPONDENCE WITH THE U.S. ATTORNEY'S

signed counsel, hereby files this motion to have defendant Epstein held in contempt for (1) failing to produce any s

DISTRICT OF FLORIDA JANE DOE, Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. CASE NO. 08-CV-80893

rosecutors, rather than statements from agents of Mr. Epstein that could be used to help build Jane Doe's case

riate to raise it now for the first time. . . . Even were the Court to consider the argument on its merits, for the reasons explained in Jane Doe's Response Memorandum (D.E. #485), pp. 4-9, the Court finds said argument without merit." Omnibus Order, case no. 9:08-cv-80119-KAM, doc. #513, at 2-3. As noted above, a

Entered on FLSD Docket 08/04/2009 Page 2 of 22 JEFFREY EPSTEIN, Defendant. JANE DOE NO. 6, CASE NO.:

, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when

nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

ppear to infringe upon or otherwise implicate Epstein's rights under the Fifth Amendment, based on the particularized showing made by Epstein in his Response Memorandum, the 8 EFTA00728601 Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 9 of 22 facts alleged in the Complaints, and t

S, individually, Defendants/Counter-Plaintiff. ORDER ON BRIEFING FOR IN CAMERA INSPECTION THIS MATTER came before the Court upon Counter-Defendant Jeffrey Epstein's ("Epstein") request for an in camera inspection of 47 e-mails that Counter-Plaintiff Bradley J. Edwards ("Edwards") claims are privileged. The Cour

endants/Counter-Plaintiff. ORDER ON BRIEFING FOR IN CAMERA INSPECTION THIS MATTER came before the Court upon Counter-Defendant Jeffrey Epstein's ("Epstein") request for an in camera inspection of 47 e-mails that Counter-Plaintiff Bradley J. Edwards ("Edwards") claims are privileged. The Court, hereby

OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

bits are overruled to permit the preparation and filing of the sealed Memorandum of Law. 6. On or before November 16, 2018, Edwards shall file his Response Memorandum of Law under seal. The Memorandum is for attorneys' eyes only and shall not be shared with Epstein. Copies of the Response Memorandum shall be deli

Page 8 2009 U.S. Dist. LEXIS 139535, * implicate the Fifth Amendment, in that by requiring 114] Epstein to list such persons or witnesses, Epstein is being forced to incriminate himself in the commission of crimes. Epstein's assertion of the Fifth Amendment as it relates to Interrogatories 1, 2

pear to infringe upon or otherwise implicate Epstein's rights under the Fifth Amendment, based on the particularized showing made by Epstein in his Response Memorandum, the facts alleged in the Complaints, and the undersigned's knowledge of the cases, it is clear they involve compelled statements that would furnis

Page 8 2009 U.S. Dist. LEXIS 139535, * implicate the Fifth Amendment, in that by requiring 114] Epstein to list such persons or witnesses, Epstein is being forced to incriminate himself in the commission of crimes. Epstein's assertion of the Fifth Amendment as it relates to Interrogatories 1, 2

pear to infringe upon or otherwise implicate Epstein's rights under the Fifth Amendment, based on the particularized showing made by Epstein in his Response Memorandum, the facts alleged in the Complaints, and the undersigned's knowledge of the cases, it is clear they involve compelled statements that would furnis