Epstein Secrets

JANE DOE NO. 102, CASE NO.: 09-CV-80656-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Plaintiff, PLAINTIFF'S RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S MOTION TO STRIKE CASES FROM CURRENT TRIAL DOCKET AND MOTION TO CONTINUE CASE AND/OR ALTERNATIVE MOTION TO MODIFY TRIAL AND SCHEDULING ORDER DEADLI

), and further states as follows: EFTA00182953 Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 4 of 9 1. Defendant EPSTEIN seeks to have this case (and others that are presently pending) stricken from the trial docket, or continued for at least an additional three month

stein by my fries' in 2002. I was to give Jeffrey Epstein a massage. I continued to provide massages up until August of 2003. I was transport I to Jeffre E)stein's house b Yellow ed b Jeffre E stein (Address will be provided upon receipt} 17. State the amount of monies (or anything else of value, including g

tered on FLSD Docket 06/08/2009 Page 4 of 9 1. Defendant EPSTEIN seeks to have this case (and others that are pre

ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff,

R No 15. List all dates you allege you were at Mr. Epstein's home in Florida, include date, time arrived an

est Palm Beach FL 33401 Phone: Attorneys for Je&ey Epstein Bruce E. Reinhart, Esquire Bruce E. Reinhart, P

the following case as supplemental authority in connection with the above referenced Motions to Compel and Replies thereto: 1. Doe v. Evans, 202 F.R.D. 173, 176 (E.D. P.A. 2001) (denying protective order where alleged sexual assault victim did not demonstrate a serious specific injury and allowing Defe

ercial sex act. Page 2 of 9 EFTA00182943 CT DATE(S) DEFENDANT(S) VICTIM(S) STATUTES/CHARGE 9 November 2004 - March 2005 --a N EPSTEIN ..NEPSTEIN Jane Doe #14 18 U.S.C. §§ 1591(aX1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaini

ravel to 358 El Brillo Way so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. Manner and Means 27. The manner and means by which the Defendants and other participants sought to accomplish the purpose and

ments to be made to, minor females in exchange for engaging in lewd conduct. EPSTEIN, (c) It was further a part of the conspiracy that Defendants JEFFREY a/k/a ," and other participants would ask females to recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (d)

the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a w

ober 28, 2006 132. Lawrence LE, Viron M, Johnson JE, Hudkins A, Samples G, Kliman G: A school-based m

SISTANT UNITED STATES ATTORNEY 52 EFTA00182941 INDICTMENT SUMMARY CT DATE(S) kEFENDANT(S) VICTIM(S) STATUTES/CHARGE 1 2001 - October 2005 NEPSTEIN Jane Does 1-19 18 U.S.C. §§ 371 and 2 Conspiracy to use a facility or means of interstate commerce to persuade, induce, or entice minors to enga

Page 9 of 15 assault. See, e.g., Aware Woman Cir., 253 F.3d at 685 (abortion); ■ 213 F.R.D. at III (infection with hepatitis B); Doe v. Evans, 202 F.R.D. 173, 176 (E.D.Pa.200 I) (sexual assault victim); Smith, 105 F.Supp.2d at 42 (sexual assault victim); WGA v. Priority Pharmacy, Inc., 184 F.R.D. 616, 61

EY EPSTEIN, Defendant. CASE NO.: 09-80469-CIV-MARRA-JOHNSON CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT, JEFFREY EPSTEIN'S REPLY TO JANE DOE NO. 101 AND JANE DOE NO. 102'S RESPONSE IN OPPOSITION TO MOTION TO COMPEL AND IDENTIFY JANE DOE NUMBERS 101 AND 102 IN THIRD PART

CASE NO.: 08-CV-8038I-MARRA/JOHNSON EFTA00182748 Case 9:08-cv-80119-KAM Document 152 Entered on FLSD Docket 06/10/2009 Page 2 of 8 Doe 101 v. Epstein Page 2 JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE

OHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 AND 10

v. Epstein Page 4 Defendant, Jeffrey Epstein, ("Mr. Epstein"), by and through his undersigned attorneys, her

ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff,

KAM Document 149 Entered on FLSD Docket 06/09/2009 Page 7 of 13 Doe 101 v. Epstein Page 7 must be shown with specificity. See Doe v. Evans, 202 F.R.D. 173, 176 (E.D. P.A. 2001). Thus, Plaintiffs have not met their burden of persuasion. N. Plaintiffs fail to show good cause in that they have not clearl

records concerning Plaintiffs is the appointment of a special master, who would verify authenticity and completeness of the records. 10. Finally, Jeffrey Epstein's request that this Court order a "sua sponte" dismissal is illogical. Sua sponte means "[w]ithout prompting or suggestion; on its own motion." Black'

the private, highly sensitive and intimate facts pertaining to their sexual assaults, and the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a well-known forensic psychiatrist with an expertise in the field of child trauma, has met with and ev

the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a w

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

Page 9 of 15 assault. See, e.g., Aware Woman Ctr., 253 F.3d at 685 (abortion); EW, 213 F.R.D. at 111 (infection with hepatitis B); Doe. Evans, 202 F.R.D. 173, 176 (E.D.Pa.2001) (sexual assault victim); Smith, 105 F.Supp.2d at 42 (sexual assault victim); WGAI Priority Pharmacy, Inc., 184 F.R.D. 616, 617 (

nt 141 Entered on FLSD Docket 06/05/2009 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN Defendant. CASE NO.:

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN Defendant. CASE NO.: 08-cv-80119-MARRA/JOHNSON CASE NO.: 08-CV-80232-MARRA/JOHNSON

IN Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 4, Plaintiff,

the following case as supplemental authority in connection with the above referenced Motions to Compel and Replies thereto: 1. Doe v. Evans, 202 F.R.D. 173, 176 (ED. P.A. 2001) (denying protective order where alleged sexual assault victim did not demonstrate a serious specific injury and allowing Defen

nt 143 Entered on FLSD Docket 06/05/2009 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN Defendant. CASE NO.:

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN Defendant. CASE NO.: 08-cv-80119-MARRA/JOHNSON CASE NO.: 08-CV-80232-MARRA/JOHNSON

IN Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 4, Plaintiff,

the following case as supplemental authority in connection with the above referenced Motions to Compel and Replies thereto: 1. Doe v. Evans, 202 F.R.D. 173, 176 (ED. P.A. 2001) (denying protective order where alleged sexual assault victim did not demonstrate a serious specific injury and allowing Defen