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

our Supreme Court, 'be judged with care .... Properly to balance these competing interests is a delicate and difficult task.' See Wright & Miller, Federal Practice & Procedure, §2040 at 286-87 (1970 ed.) (Emphasis added). EFTA00723287 v. Epstein Case No. 502008CA037319XXXXIM AB Epstein's Objections to BB's Request end

009 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO. 3, MOTION TO CONSOLIDATE CASES FOR PURPOSES OF DISCO

least twice, and as discussed below, most likely three times. Plaintiff Jane Doe No. 3 alleges that she is a victim of sexual assault by Defendant Epstein. To compel her to sit for deposition by Epstein's attorney more than once would be unduly traumatizing, burdensome, annoying, harassing and, most i

ant to Fed.R.Civ.P. 42(a). II. Background and Relevant Facts The cases Jane Doe No. 2'. Epstein case no. 08-CV-80119-Marra/Johnson Jane Doe No. 3 I. Epstein, case no. 08-CV-80232- Marra/Johnson, Jane Doe No. 4'. Epstein, 08-CV-80380- MARRA/JOHNSON, Jane Doe No. 5'. Epstein, case no. 08-CV-80387- Marra/Joh

alleges that she is a victim of sexual assault by Defendant Epstein. To compel her to sit for deposition by Epstein'

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. MOTION FOR PROTECTIVE ORDER

their pretrial stage, under many circumstances, will be a desirable administrative technique and is within the power of the Court." Wright & Miller, Federal Practice & Procedure §2382 (2008). See also Eagle Building Technologies 209 F.R.C. 499, 501 (S.D. Fla. 2002) (noting that Court has broad discretion under Rule 42(a) t

defendant-appellant Miguel Plascencia-Alvarado. Jeffrey E. Ellis, Law Offices of Ellis, Holmes & Witchley,

defendant-appellant Miguel Plascencia-Alvarado. Jeffrey E. Ellis, Law Offices of Ellis, Holmes & Witchley,

nel's final decision. Today, we confirm our prior ruling and grant the government's (unopposed) motion. FN3.See a1so3 Charles Alan Wright et al., Federal Practice & Procedure § 524 (3d ed.) (reporting that Rule 32 was amended to respond to "the concern that the vitally important sentencing decision will be made roneous