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

e is not a material fact in controversy pursuant to which the Request could lead to the discovery of relevant and admissible evidence. 17. cite to Harrell v. Hense, 2009 Wt. 409875 (C.D.CaI.) could not better support Epstein's argument herein. Harrell involves a matter where the petitioner was EFTA007

ivities of Mr. Scott Rothstein as a result of Mr. Jeffrey Epstein's lawsuit against Mr. Edwards have been disseminat

ictim... www.palmbeachdailynews.cominewsfiocal/...epstein.../CZ14sOESb004ribinjc1hU • Oct 20. 2013 - One o

dophile-jeffrey-epstein-pays-5- million-to-settle-lawsuits.php fullcontentdaily.com girlsjustwannahaveguns.corn/pedophile-paradise-lawsuit-against- jeffery-epstein-reveals-bill-clinton-visited-epsteins-orgies-mansion- multiple-times/ girlsjustwannahavegun s.com ijr.corn/2015/01/227197-clinton-epstein-lawsuit/

Bradley J. Edwards in the case originally styled Jeffrey Epstein, Plaintiff, vs. Scott Rothstein, individu

legal activities of Mr. Rothstein as a result of Mr. Epstein's lawsuit as the defaming statements, the statem

ies of Mr. Scott Rothstein as a result of Mr. Jef•ey Epstein's lawsuit against Mr. Edwards? 3 EFTA00601579

eeting 2017 (ASIST2017). Washington, DC. 27 Oct. - 1 Nov. Salminen, J.O., $engiin, S., Kwak, H., and Jansen, B.J., An, J., Jung, S.G., Vieweg, S., Harrell, F. (2017) Generating Cultural Personas From Social Data: A Perspective of Middle Eastern Users. The Fourth International Symposium on Social Networ

due by 5/29/2009), MOTION to identify jane doe #102 in the third-party subpoenas for purposes of discovery, with incorporated memorandum of law by Jeffrey Epstein.(see docket entry 5 for image) (tas) (Entered: 05/12/2009) https://eef.flsd.uscourts.gov/egi-bin/DktRpt.p17825839498761356-L_801 0-1 6/10/2009 EFTA001

09-80656-CIV-Ryskamp JANE DOE No. 102, Plaintiff, v. JEFFREY EPSTEIN, Defendant, RESPONSE IN OPPOSITION TO MOTION TO PROCEED ANONYMOUSLY AND EPSTEIN'S MOTION TO COMPEL AND/OR IDENTIFY JANE DOE #102 IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE #102 IN THIRD-PARTY SUBPOENAS FOR PURPOS

erve so Epstein can defend this case. In support, Mr. Epstein states as follows: EFTA00175214 • Case 9:09-c

10/03/2008 4 r 82.8 KB ACKNOWLEDGMENT OF SERVICE Executed as to 2 Summons Issued, 1 Complaint Acknowledgement filed by Jane Doe No. 7. (Herman, Jeffrey) (Entered: 10/03/2008) 10/03/2008 5 fi 26.1 Ica NOTICE of Striking 4 Acknowledgment of Service filed by Jane Doe No. 7 by Jane Doe No. 7 (Her

175301 CM/Eg - Live Database - flsd Page 4 of 7 05/20/2009 18 n NOTICE by of Filing Withdrawal of Previously Raised Objections to Defendant, Jeey Epstein's Motion to Compel And/Or Identify in the Style of This Case and Motion to Identify . in Third-Party Subpoenas for Purposes of Discovery, Or, Altern

7 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S FIRST AMENDED ANSWER & AFFIRMATIVE DEFENSES TO

the action to state court. The Court finds that the issues of economy, convenience, fairness and comity collectively weigh in favor of remand. See Harrell, 934 F.2d at 205. Comity weighs especially strong, given that the remaining claims are pure state law claims with no connection to federal law. Econ

cument 36 Entered on FLSD Docket 06/12/2009 Page 1 of 19 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EP

IN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, through counsel, opposes Defendant's RICHARD EPSTEIN's Motion to Dismiss. Defendant's argument for a di

FF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, thro

ISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469

red on FLSD Docket 06/12/2009 Page 4 of 19 that the issues of economy, convenience, fairness and comity collectively weigh in favor of remand. See Harrell, 934 F.2d at 205. Comity weighs especially strong, given that the remaining claims are pure state law claims with no connection to federal law. Econ

1. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION TO SET ASIDE CLERK'S ENTRY OF DEFAULT THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Set Aside Clerk's Default (DE 11), filed June 13, 2008. The motion is now fully briefed and is ripe for review. The Court has carefully c

JOHNSON JANE DOE NO. 4, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION TO SET

V-MARRA/JOHNSON JANE DOE NO. 4, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION

783 (11th Cir. 1993). To obtain relief under Rule 55(c), the movant must only make a "bare minimum showing" to support her claim for relief. Jones, Harrell, 858 F.2d 667, 669 (11'h Cir. 1988). In evaluating whether a movant has demonstrated "good cause," courts have considered several potential factor

1. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION TO SET ASIDE CLERK'S ENTRY OF DEFAULT THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Set Aside Clerk's Default (DE 9), filed June 13, 2008. The motion is now fully briefed and is ripe for review. The Court has carefully co

JOHNSON JANE DOE NO. 5, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION TO SET

V-MARRA/JOHNSON JANE DOE NO. 5, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION

783 (11th Cir. 1993). To obtain relief under Rule 55(c), the movant must only make a "bare minimum showing" to support her claim for relief. Jones. Harrell, 858 F.2d 667, 669 (11'h Cir. 1988). In evaluating whether a movant has demonstrated "good cause," courts have considered several potential factor