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

g discovery must demonstrate specifically how the objected-to request is unreasonable or otherwise unduly burdensome. See Fed. R. Civ. P. 33(b)(4); Panola Land Buyers Ass'n v. Shuman, 762 F.2d 1550, 1559 (11th Cir. 1985); Rossbach, 128 F.Supp.2d at 1353. Thus, to even merit consideration, "an objection must show

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-cv-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. CASE NO.: 08-CV-80380-MARRA/JOHNSON

s Of Discovery, Or Alternatively, Motion To Dismiss Sua Sponte, With Incorporated Memorandum Of Law 3 EFTA00725743 Defendant, JEITREY EPSTEIN ("Epstein" or "Defendant"), by and through his undersigned attorneys, hereby files his Reply to Plaintiffs', Jane Does 2-7, Response in Opposition to Epstein

NO.: 08-cv-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, CASE NO.: 0

m Of Law (the "Motion to Identify"). In support, Mr. Epstein states as follows: I. Introduction 1. Prior t

Fed.R.Civ.Pro 33(b)(4)(Plaintiffs must show that the requests are unreasonable or burdensome, which they have failed to do in the instant matter); Panola Land Buyers Ass'n v. Shuman 762 F.2d 1550, 1559 (11'h Cir. 1985); Ward v. Estaleiro Itaiai S/A, 541 F.Supp.2d 1344, 1353-54 (S.D. Fla. 2008) (discussing the ru

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

g discovery must demonstrate specifically how the objected-to request is unreasonable or otherwise unduly burdensome. See Fed. R. Clv. P. 33(b)(4); Panola Land Buyers Ass'n v. Shuman, 762 F.2d 1550, 1559 (11th Cir. 1985); Rossbach 128 F.Supp.2d at 1353. Thus, to even merit consideration, "an objection must show s

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

g discovery must demonstrate specifically how the objected-to request is unreasonable or otherwise unduly burdensome. See Fed. R. Civ. P. 33(b)(4); Panola Land Buyers Ass'n v. Shuman, 762 F.2d 1550, 1559 (11th Cir. 1985); Rossbach, 128 F.Supp.2d at 1353. Thus, to even merit consideration, "an objection must show

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

g discovery must demonstrate specifically how the objected-to request is unreasonable or otherwise unduly burdensome. See Fed. R. Civ. P. 33(b)(4); Panola Land Buyers Ass'n v. Shuman, 762 F.2d 1550, 1559 (11th Cir. 1985); Rossbach, 128 F.Supp.2d at 1353. Thus, to even merit consideration, "an objection must show