3
Shared Docs
3
Same-Page
3 / 3
Mentions
provide "broad access" to relevant information. Ross I. Buckeye Cellulose Corp., 980 F.2d 648, 661 (1
belief," that victims' counsel "did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's [i.e., I role (or lack thereof) in the Epstein investigation." Intervenor's Motion for Sanction at 5. The motion further complaine
civil case, Case No. 08-807346-Civ-Marra. Of course, in civil cases "liberal civil discovery rules" provide "broad access" to relevant information. Ross v. Buckeye Cellulose Corp., 980 F.2d 648, 661 (11th Cir. 1993). Jane Doe #1 and Jane Doe #2 should be able to avail themselves of those rules to de
belief," that victims' counsel "did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's [i.e., Reinhart's] role (or lack thereof) in the Epstein investigation." Intervenor's Motion for Sanction at 5. The motion further
cluding but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. Further, upon
On information and belief, they did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's role (or lack thereof) in the Epstein investigation. Had they done so, they would have learned that there were approximately 20 As
Entities connected to both Wilbur Ross and the West Palm Beach Office

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Marc Rich
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Eric Trump
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Supreme Court
ORGANIZATION
Prince Charles
PERSON
Barry Diller
PERSON
Michael Jackson
PERSON
Scarlett Johansson
PERSONMartin Weinberg
PERSON
Bradley Edwards
PERSONFBI
ORGANIZATIONthe Southern District
LOCATION
James Baker
PERSON