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

0119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 14 of 22 unreasonable or otherwise unduly burdensome."); Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001)("the burden of showing that the requested information is not relevant to the issues in the case is on the party

tein 12889705 NCA customised Closed - liit 16/06/2017 BIS RESULTS: Negative Media: Mali On I ine MailOnline May 24, 2017 Wednesday 10:53 PM GMT Jeffrey Epstein's 'sex slave' settles her defamation lawsuit against British socia xwell who 'passed her around for sex' and trained her to be 'everything a man wa

recruited her as a sex slave when she was 15 for convicted pedophile billionaire Jeffrey Epstein and passed around to his friends Maxwell, who was Epstein's girlfriend at the time, is also accused of forcing her to have sex with Maxwell and other underage girls The 55-year-old responded to the allegat

ion of Reed Elsevier Inc. All Rights Reserved. Date:6/16/2017 Report processed by: DEUTSCHE BANK AGII Full Name Address County Phone EPSTEIN. JEFFERY E 9 E 71ST ST NEW YORK (212) 750-9895 NEW YORK. NY 10021-4102 (212) 249.1122 NEW YORK COUNTY (212) 772-9416 ADDITIONAL PERSONAL INFORMATION SSN

2546965 (Age 64) Subject Summary Name Variations 1: EDWARDS. JEFFERY 2: EPSTEIN, J 3: EPSTEIN, JEFFERY 4: EPSTEIN, JEFFERY E 5: EPSTEIN, JEFFREY 6: EPSTEIN. JEFFREY E 7: EPSTEIN. JERRERY 8: EPSTIEN, JEFFERY 9: EPTSTEIN. JEFFERY SSNs Summary No. SSN 1: 090-44-XXXX DOBs Reported DO

N. MARK L SSN:117-444OOCX DOB:1955 (Age: 62) EPSTEIN, PAULA A Deceased • AKA EPSTEIN, PAULINE SSN:050-09-XXXX DOB:10/1918 (Age: 98) TUCKER. ELLYN EPSTEIN • AKA EPSTEIN, ELLY • AKA EPSTEIN, ELLYN ELLYN • AKA EPSTEINTUCKER. ELLYN EPSTEIN • AKA EPSTEIN. E • AKA TUCKER. EPSTEIN ELLYN • AKA EPSTEIN-TU

the subject matter of the action." Milinazzo v. State Farm Ins. Co., 247 F.R.D. 691, 695-96 (S.D. Fla. 2007) (citing Dunkin' Donuts, Inc. v. Mary's Donuts, Inc., No. 01- 0392, 2001 U.S. Dist. LEXIS 25205, 2001 WL 34079319, at *2 (S.D. Fla. Nov. 1, 2001)). 1. Request No. 1--the FBI File on the Epstein Matter

ent 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARR A/JOHNSON Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,

4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders (DE 462)

o. 19 Beach State Attorney and the USAO may not want to disclose their files for one reason or another. (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NPA is

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

d for the tax returns exists because the information contained therein is not otherwise available. W. at *2; see also Dunkin Donuts, Inc. v. Marv's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001); EFTA00317234 Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 25 of 37 Doe v. Epste

HE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS TO ANSWER OUESTIONS Plaintiff/Counter-Defendant Jeffrey Epste

ON TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS TO ANSWER OUESTIONS Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.380(a) of the Florida Rules of Civil Procedure, hereby moves this Court for entry

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

you put into Q-task regarding the claims against Mr. Epstein? Transcript of Deposition dated March 23, 2010, p

complaint, even if the information requested through questioning implicitly reveals his legal theory of his case. See Dunkin Donuts Inc. v. Mary's Donuts, Inc., 206 F.R.D. 518 (S.D. Fla. 2002) (work product privilege may not be asserted by deponent to avoid providing information supporting contentions in p

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

9-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 14 of 22 unreasonable or otherwise unduly burdensome."); Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001)("the burden of showing that the requested information is not relevant to the issues in the case is on the party

ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE I). The parties and intervenors d

o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that

the subject matter of the action." Milinazzo v. State Farm Ins. Co., 247 F.R.D. 691, 695-96 (S.D. Fla. 2007) (citing Dunkin' Donuts, Inc. v. Mary's Donuts, Inc., No. 01-0392, 2001 WL 34079319, at *2 (S.D. Fla. Nov. 1, 2001)). 1. Request No. 1—the FBI File on the Epstein Matter and Indictment Material In th

ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE 1). The parties and intervenors d

o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that

n the subject matter of the action." Milinazzo v. State Farm Ins. Co. 247 F.R.D. 691, 695-96 (S.D. Fla. 2007) (citing Dunkin' Donuts, Inc. v. Mary's Donuts, Inc., No. 01-0392, 2001 WL 34079319, at •2 (S.D. Fla. Nov. 1, 2001)). 1. Request No. 1—the FBI File on the Epstein Matter and Indictment Material In th

would therefore violate the Constitution; overly broad. As set forth in more detail in DE 282 and 283, which were provided to the court in camera, Epstein cannot provide answers/responses to questions relating to his financial history and condition without waiving his Fifth, Sixth, and Fourteenth Amend

for the tax returns exists because the information contained therein is not otherwise available. Id. at *2; see also Dunkin Donuts, Inc. v. Marv's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001)• Cooper v. Hallgarten & Co. 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production o

would therefore violate the Constitution; overly broad. As set forth in more detail in DE 282 and 283, which were provided to the court in camera, Epstein cannot provide answers/responses to questions relating to his financial history and condition without waiving his Fifth, Sixth, and Fourteenth Amend

for the tax returns exists because the information contained therein is not otherwise available. Id. at *2; see also Dunkin Donuts, Inc. v. Marv's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001)• Cooper v. Hallgarten & Co. 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production o

Page 10 2009 U.S. Dist. LEXIS 139535, * As for Epstein's non-privileged based objections, ["20] such as relevance, over breadth, over burdensomeness, and alleged HIPAA protection, said objections are als

onstrate specifically how the objected-to information is unnecessary, unreasonable or otherwise unduly burdensome."); Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001 U.S. Dist. LEXIS 25205, 2001 WL 34079319 (S.D. Fla. 2001)("the burden of showing that the requested information is not relevant to the issues