Epstein Secrets

Six, to-wit: The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State aforesaid, COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between t

ion For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing this action for a time certain

13 In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable cause to apprehend danger from a

of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, i

of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in

attorney for JEFFREY EPSTEIN. 3. I represented Mr. EPSTEIN in the negotiation of and entering into a Non-Pr

ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.

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

ame in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Response: Defend

EFTA00067399 Case 9:08-cv-80119-KAM Document 65-4 Entered on FLSD Docket 03/25/2009 Page 3 of 37 Jane Doe No. 2 v. Epstein Page 3 DEFENDANT JEFFREY EPSTEIN'S ANSWERS AND OBJECTIONS TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES Interrogatory No. 1. Identify all employees who performed work of servi

CT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE & OBJECTIONS TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys,

2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE & OBJECTIONS TO PLAINTIFF'S AMENDED F

ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.

s. V. PLAINTIFF IS ENTITLED TO DEFENDANT'S HEALTH CARE INFORMATION IN DISCOVERY A. Interrogatory at Issue "Interrogatory No. 8. Identify all of Jeffrey Epstein's health care providers in the past (10) ten years, including without limitation, psychologists, psychiatrists, mental health counselors, physician,

to Plaintiff's discovery requests. - 1 - EFTA00728201 Case 9:08-cv-80119-KAM Document 57 Entered on FLSD Docket 03/02/2009 Page 2 of 16 II. EPSTEIN'S BLANKET ASSERTION OF PRIVILEGE AGAINST SELF-INCRIMINATION IN RESPONSES TO INTERROGATORIES IS INSUFFICIENT Defendant's response to each and every

cceptable). While Plaintiff does not dispute that Defendant Epstein's Fifth Amendment privilege may be asserted in a

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION TO COMPE

ame in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Response: Defend

ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.

CT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, I. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS TO PLAINTIFF'S AMENDED FIRST REQUEST FOR PRODUCTION Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, serv

st provided to you by the U.S. Attorney of individuals whom the U.S. Attorney was prepared to name in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constituti

9-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, I. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

ame in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Response: Defend

ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.