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

reasonably calculated to lead to the discovery of admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans.. Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Contrary to Plaintiffs assertion, Rule 412 does not automatically result in a determination that such sexual history and sexual a

bove cause, testified on his oath as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR. SCAROLA: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each of your residence addresses? MR. GOLDBERGER: I think it's beyond the scope. I'm going to object to Fifth

wed to intervene in this action, now respectfully submits this Motion to Compel Jeffrey Epstein to Provide Answers to Deposition Questions. Because Epstein has improperly refused to answer multiple questions at his recent deposition, the motion should be granted. Relevant Factual Background The facts

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

he Agreed Order." DE 6366 at 5 (citing DE 1194). Mr. Epstein improperly refused to answer many questions about

long as the information is reasonably calculated to lead to the discovery of admissible evidence." Donahay v. Palm Beach Tours & Transp., Inc„ 242 F.R.D. 685, 687 (S.D. Fla. 2007) (internal quotations omitted). The burden is on the party asserting a privilege or other basis for refusing to answer a depos

limit, yet her proposed depositions are not calculated to lead to admissible evidence in this case. By way of example, Plaintiff identifies ), and Jeffrey Epstein as alleged "co-conspirators" with each other. She requests the depositions of each. Plaintiff anticipates each will invoke the Fifth Amendment — in

harassing questions Plaintiff posed to her concerning her adult, consensual sexual activities. In other words, depositions of Marcincova, Kellen and Epstein would serve Plaintiff's goal to make a convoluted legal argument, not to actually seek discoverable information. In light of this, the "burden or e

UMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. E

and (identified as assistants to Ms. Maxwell or Mr. Epstein). The information Plaintiff claims each of the wi

individuals may have discoverable information does not necessarily entitle a party to depose each such individual." Dixon v. Certainteed Corp., 164 F.R.D. 685, 692 (D.Kan.1996). "The factors relevant to determining whether a party should be entitled to more than ten depositions are now set forth in Fed.R.

/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

reasonably calculated to lead to the discovery of admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Discoverability of such information is governed by Rule 26, Fed.R.Civ.P., pursuant to which the scope of discovery is broad. Dona

2015, the Government provided answers to some of the discovery requests. With regard to the discovery requests concerning information about one of Jeffrey Epstein's defense attorneys, Alan Dershowitz, the Government refused to provide any information, asserting that any information about Dershowitz was irrelevan

ent would either produce that information or produce an appropriate privilege log.' The victims believe that the discovery requests regarding one of Epstein's defense attorneys are reasonably calculated to lead to the discovery of admissible evidence, for all the reasons explained in this memorandum. Fo

ery requests concerning information about one of Jeffrey Epstein's defense attorneys, Alan Dershowitz, the

e general course of this proceeding. DE 330 at 23 (internal quotation omitted). 8 EFTA00210995 Donahay I. Palm Beach Tours & Transp., Inc,., 242 F.R.D. 685, 687 (S.D. Fla. 2007) (internal quotations omitted). The Federal Rules of Civil Procedure are broadly written and "strongly favor full discovery w