Epstein Secrets

2/2009 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, To ANSWER DEFENDANT'S FIRST SET OF INTERROGATORIES AND TO OVERRULE OB

ICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, To ANSWER DEFENDANT'S FIRST SET OF INTERROGATORIES AND TO OVERRULE OBJECTIONS, AND FOR AN AWARD OF D

2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, To

19-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION

resses and phone numbers of all males, excluding Mr. Epstein, with whom you have had sexual activity since age

conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu

EY EPSTEIN, Defendant. CASE NO.: 09-80469-CIV-MARRA-JOHNSON CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT, JEFFREY EPSTEIN'S REPLY TO JANE DOE NO. 101 AND JANE DOE NO. 102'S RESPONSE IN OPPOSITION TO MOTION TO COMPEL AND IDENTIFY JANE DOE NUMBERS 101 AND 102 IN THIRD PART

CASE NO.: 08-CV-8038I-MARRA/JOHNSON EFTA00182748 Case 9:08-cv-80119-KAM Document 152 Entered on FLSD Docket 06/10/2009 Page 2 of 8 Doe 101 v. Epstein Page 2 JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE

OHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 AND 10

v. Epstein Page 4 Defendant, Jeffrey Epstein, ("Mr. Epstein"), by and through his undersigned attorneys, her

ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff,

l conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu

/2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE & TO OVERRULE OBJE

ICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE & TO OVERRULE OBJECTIONS. & FOR AN AWARD OF DEFEND

2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO

19-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION

conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu

2009 Page 1 of 9 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. JANE DOE NO. 4, CASE NO.: 08-CV-8

ant. JANE DOE NO. 7, CASE NO.: 08- 80993-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFFS' MEMORANDUM IN OPPOSITION TO EPSTEIN'S MOTION TO COMPEL ANSWERS TO FIRST SET OF INTERROGATORIES AND FOR AN AWARD OF REASONABLE EXPENSES Plaintiffs, JANE DOES 2-7, by and through their

xpenses, and state as follows: I. Introduction Defendant Epstein served an Interrogatory (# 18) seeking to unearth

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

urt "must impose certain restriction on discovery to preclude inquiry into areas which will clearly fail to satisfy the balancing test" set forth in Rule 412. See Barta I. City and County of Honolulu, 169 F.R.D. at 135. In Barta, the Court confronted this issue in the context of a discovery motion in a c

if you want to, we can schedule this so you can have lunch. On the other hand, if you don't want lunch, that's okay. I can endure. By the way, the Epstein motion will go over to tomorrow because we were told, if I understand it correctly, that they didn't know it was on for today. How that ignorance

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 deals with the admissibility of things like the nonprosecution agreement, Jeffrey Epstein's plea, his sex offender registration, because if it relates to Ms. Maxwell's statement or the statement that Ms. Maxwell refers to, then it's relev

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. McCAWLEY: Well, we're entitled to ask her on the stand; we're entitled to ask Jeffrey what he told her. THE COURT: That's a different issue. That's a different issue. I mean, that's a wholly different thing. You're talking about you

ure off her and to satisfy the sexual desires of Mr. Epstein. That's why there was this vast -- THE COURT: An

22 23 24 25 problem. Well, no, it isn't. No, it isn't. Okay. So let's do 675. MS. MENNINGER: Your Honor, I will say that it is my reading of Rule 412 that any hearing that is based upon in part Rule 412 is supposed to be conducted in a in camera setting. MS. SCHULTZ: Counsel for Ms. has no objec

the Plaintiff's circle of friends, family and community, but who are unaware that she is a civil Plaintiff making claims of child sex abuse against Jeffrey Epstein. While the investigators may not be stating to these persons directly that the Plaintiff is 1 Jane Doe No. 4 has submitted two Declarations, dated J

2-7 REPLY MEMORANDUM IN SUPPORT OF MOTION FOR PROTECTIVE ORDER Summary of Argument in Reply Through hyperbole and grandiose statements, Defendant Epstein seeks to mask the true purpose and motive of his private "investigation" into the Plaintiffs' claims. The private investigators' activities, some o

eply Through hyperbole and grandiose statements, Defendant Epstein seeks to mask the true purpose and motive of his

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related Cases: 08-80232, 0

9-KAM Document 266 Entered on FLSD Docket 08/14/2009 Page 7 of 9 history, thereby evading the limitations on discovery and admissibility found in Rule 412 for the only conceivable purpose of harassing the Plaintiff. Defendant asserts that he seeks to use investigators to ask ex-boyfriends and friends

51 H3ulgiva 1 in 2015, which is, all of these allegations that deal with 2 Jeffrey Epstein and Ghislaine Maxwell, all of those allegations 3 are untrue, she has the ability to know all of the public 4 information that would tell her thi

talked to people who think that comes under the transcript, who is then says: Well, you know, I know that were alleged as co-conspirators, and I Epstein's privilege. Mr. Edwards, in a party litigant, says: She wasn't a co-conspirator. That's what he says in this transcript, which you will see. He m

EFTA00794477 (212) 805-0300 EFTA00794478 57 H3ulgiva 1 MS. McCAWLEY: Well, we're entitled to ask her on the 2 stand; we're entitled to ask Jeffrey what he told her. 3 THE COURT: That's a different issue. That's a 4 different issue. I mean, that's a wholly different thing. 5 You're talking

laintiff's allegations that prior to ever meeting Mr. Epstein 3 or Ms. Maxwell, she was the victim of sex tra

same 2 problem. Well, no, it isn't. No, it isn't. 3 Okay. So let's do 675. 4 MS. MENNINGER: Your Honor, I will say that it is my 5 reading of Rule 412 that any hearing that is based upon in part 6 Rule 412 is supposed to be conducted in a in camera setting. 7 MS. SCHULTZ: Counsel for Ms. has no

ice so we can raise the issue with the Court if necessary. 2. Do you intend to offer evidence or argument that the defendant is a victim of abuse by Jeffrey Epstein? If so, we are assessing whether we would move on that in limine on Monday, so please let us know as soon as you can. Thanks, From: Christian Ever

hat the defendant is a victim of abuse by Jeffrey Epstein? If so, we are assessing whether we would move o

gument that the defendant is a victim of abuse by Jeffrey Epstein? If so, we are assessing whether we woul

iven serious consideration to your request to set a briefing schedule for the Rule 412 motion. After reflection, we believe the timeline provided in Rule 412 is appropriate and we do not agree that any earlier briefing schedule makes sense here in light of the fact that we just received the voluminous 350

ice so we can raise the issue with the Court if necessary. 2. Do you intend to offer evidence or argument that the defendant is a victim of abuse by Jeffrey Epstein? If so, we are assessing whether we would move on that in limine on Monday, so please let us know as soon as you can. Thanks, From: Christian Ever

hat the defendant is a victim of abuse by Jeffrey Epstein? If so, we are assessing whether we would move o

gument that the defendant is a victim of abuse by Jeffrey Epstein? If so, we are assessing whether we woul

iven serious consideration to your request to set a briefing schedule for the Rule 412 motion. After reflection, we believe the timeline provided in Rule 412 is appropriate and we do not agree that any earlier briefing schedule makes sense here in light of the fact that we just received the voluminous 350

tends represent "direct evidence" of a conspiracy (to recruit, groom, and sexually abuse minor females or to entice, transport or traffic them for Jeffrey Epstein's sexual pleasure) that Resp. at 36. 2 The proffered evidence is found at GX 401-404, 409-410 and 413 7 EFTA00090733 The government contends that

government clearly intends to rely on how open the alleged abuse was, the relevance of evidence that even the people who claim they were abused by Epstein during the same time frame but without any knowledge or participation by Ms. Maxwell becomes highly relevant to rebut such testimony. 12 EFTA00090

ELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN &

inor probative value the evidence has is substantially outweighed by the danger of unfair prejudice. Fed. R. Evid. 401, 403. And as explained in the Rule 412 motion today, if offers testimony and the government presents argument 22 EFTA00090748 along these lines, that will open the door to other sexu