Epstein Secrets

2009 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S REPLY MEMORANDUM IN SUPPORT OF MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA, AND MOTION TO CONSOLIDATE FOR PURPOSES

mmon and overlapping facts in these cases, there is no reason why a party witness cannot be questioned in a single sitting on all facts pertinent to Epstein. A protective order is therefore warranted in these cases so that each Plaintiff has her deposition taken only once. Conclusion Based on the foreg

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S REPLY MEMORANDU

efendant also asserts without support or explanation that "confusion will result and motions in limine will undoubtedly be filed. . . ." In Ramsay,. Broward County Sheriff's Office, 303 Fed. Appx. 761, 2008 WL 5237162 (11th Cir. 2008), the Court affirmed the District ' In a case relied upon by Defendant, Kelly I. Kelly,

rls for sexual reasons, were you surprised? A. I didn't believe it. Q. Do you believe it today? A. I don't believe it. Q. You don't believe that Jeffrey Epstein was involved with underage girls in a sexual way? MR. CRITTON: Form. THE WITNESS: You're asking for my opinion, and I don't think my opinion is

ndividually, L.M., individually, E.W., individually, and JANE DOE, individually Defendants. COMPLAINT Plaintiff, JEFFERY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individua

L CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1

om probably have served on various Florida Bar committees. Yet they claim a lack of knowledge when: a. The firm had 24 hour security in the form of Broward County Sheriff's officers on each floor of the offices; b. ROTHSTEIN had 24 hour (firm paid) security at his home; c. Partners/attorneys/staff could not directly a

FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED TRIAL WITNESSES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his Amended Trial Witness List as follows: TRIAL WIT

040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED TRIAL WITNESSES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his Amended Trial Witness List as follows: TRIAL WITNESSES I. Scott W. Rothstein do Marc Nurik, Esq. Law Offices of Marc S. Nuri

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

Scott W. Rothstein do Marc Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 2. Ken Jenne do Broward County Sheriff's Office 2601 W. Broward Blvd. Ft. Lauderdale, FL 33312-1308 EFTA00798218 3. William Scherer c/o Conrad & Scherer, LLP 633 S. Federal Highway,

s and participants who worked on the "Epstein Cases" while they were being prosecuted by RRA; denial of access to discovery and other information to Epstein during this lawsuit. 8 Tonja Haddad, P.A. • 315 SE 7°' Street, Fort Lauderdale, FL 33301 EFTA00799372 42. John Scarola, Esq. Searcy Denney Sca

leadings and activity in the "Epstein Cases" while at RRA; denial of access to discovery and other information to Epstein during this lawsuit. 43. Jeffrey Epstein do Tonja Haddad, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 Depending on the testimony of witnesses and evidence presented by

information to Epstein during this lawsuit. 43. Jeffrey Epstein do Tonja Haddad, PA 315 SE 7th Street

auderdale, FL 33301 He is expected to testify regarding the Ponzi scheme, use of the "Epstein Cases" in the furtherance thereof. 2. Ken Jenne do Broward County Sheriff's Office 2601 W. Broward Blvd. Ft. Lauderdale, FL 33312-1308 He is expected to testify regarding the Ponzi scheme, use of the "Epstein Cases" in the

FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED TRIAL WITNESSES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his Amended Trial Witness List as follows: TRIAL WIT

040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED TRIAL WITNESSES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his Amended Trial Witness List as follows: TRIAL WITNESSES I. Scott W. Rothstein do Marc Nurik, Esq. Law Offices of Marc S. Nuri

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

Scott W. Rothstein do Marc Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 2. Ken Jenne do Broward County Sheriff's Office 2601 W. Broward Blvd. Ft. Lauderdale, FL 33312-1308 EFTA00799460 3. William Scherer c/o Conrad & Scherer, LLP 633 S. Federal Highway,

ure by Q and by Trump. Others obsess over the intelligence community and the notion of a deep state. An active subsection of Q followers probes the Jeffrey https://www.theatlantic.com/magazine/archive/2020/06/qanon-nothing-can-stop-what-is-coming/810567/ Page 25 of 38 EFTA01660458 QAnon Is More Impo

qanon-nothing-can-stop-what-is-coming/810567/ Page 25 of 38 EFTA01660458 QAnon Is More Important Than You Think - The Atlantic 6(11)20, 9:20 AM Epstein case. There are those who claim knowledge of a 16-year plan by Hillary Clinton and Barack Obama to destroy the United States by means of mass droug

ntic 6111/20, 9:20 AM V. WHO IS Q? ANY NEW BELIEF SYSTEM runs into opposition. In December 2018, Matt Patten, a veteran SWAT-team sergeant in the Broward County Sheriff's Office, in Florida, was photographed with Vice President Mike Pence on an airport tarmac. Patten wore a patch on his tactical vest that bore the l