Epstein Secrets

ung girls were also blocked because Epstein's co-conspirators (i.e., also took the Fifth on every question posed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficulty of obtaining discovery from Epstein and his co-conspirators, Edwards was force

osed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Becau

question posed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12

issible discovery. The requested materials 15 EFTA00708307 Case 09-34791-RBR Doc 1603 Filed 04;08:11 Page 16 of 23 are not discoverable under the Florida Rules of Civil Procedure, the Federal Rules of Civil Procedure, the Bankruptcy Rules of Civil Procedure or any other possibly applicable system of rules. Moreover, the docu

shared with any non-lawyer) which communication references directly or indirectly Bradley Edwards, this pending litigation or litigation involving Ghislaine Maxwell. ANSWER: No responsive documents exist. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below,

ing litigation or litigation involving Ghislaine Maxwell. ANSWER: No responsive documents exist. WE HER

this pending litigation or litigation involving Ghislaine Maxwell. ANSWER: No responsive documents exist.

QUEST FOR PRODUCTION Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby responds to Defendant/Counter-Plaintiff Bradley Edward's Request for Production to Counter-Defendant as follows: 1. Any and all documents

Courts in Florida may take steps to protect against pretrial publicity. See Shepnard v. - 2 - EFTA00616237 CASE NO. 50 2009 CA 040800 XXXXMB AG Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 16 I Ed. 2d 600 (1966); Sentinel Communications Co. v. Watson, 615 So. 2d 768, 769 (Fla. 5th DCA 1993). The limi

to give evidence in two separate legal cases involving Jeffrey Epstein, his paedophile friend, The Daily Telegraph has learnt. Jeffrey Epstein and Ghislaine Maxwell stayed at Sandringham as guests of the puke Photo: ALF3ANPIX/GEOFF PUGH By Jon Swaine (http://www.telegraph.co.uk/joumalists/jon-swaine0 , in Palm B

ne of Prince Andrew's more controversial friends. A decade ago, he was reported to have accompanied her to a "hookers and pimps" party in New York. Ghislaine moved to the US in 1991 after the death of her father and became a fixture on the Manhattan party circuit, where she befriended Jeffrey Epstein. ■

LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Motion for Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extra-Judicial Statements and Comm

DOE, will take the deposition of Ghislane Noelle Maxwell on Monday, August 17, 2009, at 11:00 a.m., at: E

Plaintiff, JANE DOE, will take the deposition of Ghislane Noelle Maxwell on Monday, August 17, 2009, at 11:

, at: McGinnis & Associates 5701 North High Street Suite 300 Worthington, OH 43085 (614) 431.1344 The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. I HEREBY CERTIFY that a true and correct copy of the foregoing has

. Cowls in Florida may take steps to protect against pretrial publicity. See Sheppard v - 2 - EFTA00599555 CASE NO. 50 2009 CA 040800 X:OO:MB AQ Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 161. Ed. 2d 600 (1966); Sentinel Communications Co. v. Watson 615 So. 2d 768, 769 (Fla. 5th DCA 1993). The limit

LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Motion for Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extra-Judicial Statements and Comm

ontrol and prohibit such extrajudicial commentary and pretrial publicity in order to insure that Mr. Epstein receives a fair trial. See Sheppard v. Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 16 L. Ed. 2d 600 (1966); State ex. reL Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976);

LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Amended Motion for a Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extrajudicial Statements

ontrol and prohibit such extrajudicial commentary and pretrial publicity in order to insure that Mr. Epstein receives a fair trial. See Sheppard v. Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 16 L. Ed. 2d 600 (1966); State ex. rel. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976)

LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Amended Motion for a Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extrajudicial Statements