Epstein Secrets

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

work product where the requesting party can show need and the inability to obtain the substantial equivalent by other means without undue hardship. Vesta Fire Ins. Corp. v. Figueroa, 821 So.2d 1233. 1234 (Fla. 5th DCA 2002)(the showing of need and undue hardship necessary to overcome the work product immunity

HE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffr

RIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rules 1.280 and 1.380 of the Florida Rules of Civil Procedure, hereby requests that this

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

tion with Edwards's prosecution of cases against Mr. Epstein before and after Edwards joined RRA. Epstein's r

roduct where the requesting party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this producti

HE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffr

RIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rules 1.280 and 1.380 of the Florida Rules of Civil Procedure, hereby requests that this

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

tion with Edwards's prosecution of cases against Mr. Epstein before and after Edwards joined RRA. Epstein's r

roduct where the requesting party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this producti

HE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffr

RIKE DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY OBJECTIONS AND COMPEL RESPONSES THERETO Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rules 1.280 and 1.380 of the Florida Rules of Civil Procedure, hereby requests that this

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

tion with Edwards's prosecution of cases against Mr. Epstein before and after Edwards joined RRA. Epstein's r

roduct where the requesting party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this producti