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

egree to which the proposed inspection will aid in the search for truth must be balanced against the burdens and dangers created by inspection." See Belcher v. Bassett Furniture Industries, Inc., 588 F.2d 904, 908 (4th Cir. 1978) (also known as "The Belcher Test"). 41. An inquiry into when to compel a

tness an individual ("Employee-1") who worked for Jeffrey Epstein immediately 35 EFTA00088837 followin

osed testimony concerns the experience of manipulated and coerced victims, rather than the intentions of perpetrators. 19 EFTA00088821 return to Epstein's home for sexual abuse, or why some occasionally expressed affection for the defendant and Epstein. Although Dr. will not testify about these spe

consideration of the Court's pretrial order denying the defense's motion to strike Minor Victim-3 from the Indictment. Evidence of the defendant and Jeffrey Epstein's abuse of Minor Victim-3 is direct evidence of the offense charged in the Indictment, including the overt acts in the Indictment that pertain to Mino

elationship between the defendant and Epstein. For instance, to the extent the defense at trial argues that the defendant was merely an employee of Epstein's, this photograph is evidence to the contrary. Sixth, the defense argues that Government Exhibit 606 lacks evidentiary foundation, is hearsay, and i

e victims' credibility based on their delayed and incomplete reports of abuse." (citations and internal quotation marks omitted)); United States v. Belcher, 534 F.3d 820, 826 (8th Cir. 2008) ("In this case, Dr. Levitt's testimony as to delayed disclosure helped the jury understand why the girls did not

Expose Epstein Files Fox News (01/30, Shaw) reported that Patel, pledged Thursday to work with a top Republican senator on exposing who worked with Jeffrey Epstein in trafficking and exploiting children. The article noted that Sen. Marsha Blackburn (R-TN), quizzed Patel about how he would handle the Epstein cas

rey Epstein in trafficking and exploiting children. The article noted that Sen. Marsha Blackburn (R-TN), quizzed Patel about how he would handle the Epstein case. The sex-trafficking financier died in 2019 while awaiting trial. Nearly 200 names that had previously been redacted from court documents in a

p Republican senator on exposing who worked with Jeffrey Epstein in trafficking and exploiting children. T

, Hannah) also reported on the story. Washington Authorities Looking for Missing Lummi Nation Elder Last Seen Jan. 21 The Bellingham Herald (01/30, Belcher) reported that the Lummi Nation Police Department, FBI, and Whatcom County Sheriff's Office are actively searching for 62-year-old Besalynn M. James

Expose Epstein Files Fox News (01/30, Shaw) reported that Patel, pledged Thursday to work with a top Republican senator on exposing who worked with Jeffrey Epstein in trafficking and exploiting children. The article noted that Sen. Marsha Blackburn (R-TN), quizzed Patel about how he would handle the Epstein cas

rey Epstein in trafficking and exploiting children. The article noted that Sen. Marsha Blackburn (R-TN), quizzed Patel about how he would handle the Epstein case. The sex-trafficking financier died in 2019 while awaiting trial. Nearly 200 names that had previously been redacted from court documents in a

p Republican senator on exposing who worked with Jeffrey Epstein in trafficking and exploiting children. T

, Hannah) also reported on the story. Washington Authorities Looking for Missing Lummi Nation Elder Last Seen Jan. 21 The Bellingham Herald (01/30, Belcher) reported that the Lummi Nation Police Department, FBI, and Whatcom County Sheriff's Office are actively searching for 62-year-old Besalynn M. James

INC. Plaintiff: CINTAS. CORPORATION Plaintiff Address: CINTAS, CORPORATION 3951 DARTMOUTH COURT FREDERICK, MD 21703 Plaintiff Attorney: LIPPMAN, JEFFREY M WEINSTOCK, FRIEDMAN,ETAL 4 RESERVOIR CIRC,2ND FLR BALTIMORE, MD 21208 Number: 0702-001450-2007 Vendor Number: DS-00001450-2007 Date: 1/17/2007

al not allowed, 89 Ohio St. 3d 1465, 732 N.E.2d 998; see, also, Trout v. Ohio Dept riii of Edn., Franklin App. No. 02AP-783, 2003 Ohio 987, at P26; Belcher v. Ohio State Racing Comm., Franklin App. No. 03AP-786, 2004 Ohio 1278, at P18, appeal not allowed, 103 Ohio St. 3d 1405, 2004 Ohio 3980, 812 N.E.2d