Epstein Secrets

ff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 401-5012 Co-Counsel for Defendant Jeffrey Epstein Respec By: D. CRI •N, JR., ESQ. Florida Bar No. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 BURMAN, CRITTON, LUTTIER & COLEMAN 515 N.

POENAS FOR PURPOSES OF DISCOVERY. OR ALTERNATIVELY, MOTION TO DISMISS SUA SPONTE, WITH INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and through his undersigned attorneys, hereby requests that this Court enter an order identifying in the style of this case th

eem just an Robert D. Ckitton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a

19-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. MOTION TO COMPEL AND/OR IDE

to Dismiss Entire Action Sua Sponte. In support, Mr. Epstein states as follows: I. Motion And Incorporated Me

o eliminate the likelihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1). see also Surf Drugs, Inc., v. Vermette 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their

Motion To Identify Defendant, JEFFREY EPSTEIN ("Mr. Epstein"), by and through his undersigned attorneys and

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN and Defendants. Defendant Epstein's Motion For Sanctions Against Spencer Kuvin, Esq. , Motion For Protective Order And Alternative Motion To Ide

ICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN and Defendants. Defendant Epstein's Motion For Sanctions Against Spencer Kuvin, Esq. , Motion For Protective Order And Alternative Motion To Identify Defendant, JEFFREY EPSTEIN ("M

laintiff, v. JEFFREY EPSTEIN and Defendants. Defendant Epstein's Motion For Sanctions Against Spencer Kuvin, Es

CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN and Defendants. Defendant Epstein's Mo

o eliminate the likelihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1); see also Surf Drugs, Inc., v. Vermette, 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their

t 05/07/2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80993-MARRA JANE DOE NO. 7, Plaintiff, v. JEFFREY EPSTEIN, Defendant. MOTION TO COMPEL AND/OR IDENTIFY JANE DOE #7 IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY SUBPOENAS FOR P

OENAS FOR PURPOSES OF DISCOVERY, OR ALTERNATIVELY, MOTION TO DISMISS SUA SPONTE, WITH INCORPORATED MEMORANDUM OF LAW1 Defendant, JEFFREY EPSTEIN ("Epstein" or °Defendant"), by and through his undersigned attorneys, hereby requests that this Court enter an order identifying in the style of this case th

-CV-80993-MARRA JANE DOE NO. 7, Plaintiff, v. JEFFREY EPSTEIN, Defendant. MOTION TO COMPEL AND/OR IDE

stress. Plaintiff alleges separate counts against Mr. Epstein, on which he must conduct discovery to defend th

o eliminate the likelihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1); see also Surf Drugs, Inc., v. Vermette, 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their