Epstein Secrets

place nor suppkniont the filing and seivice of pkadings or whet papers a by local mks of :oat. Tins form. approwed by the Judicial Conference of 'he United Stales In Septanba 1974. is required for the use of the Clerk tX Civil cockei nett SEE INSTRUC TIOVS ON THE REVERSE OF THE FORM.' NOTICE: Attorneys MUST

n "ancillary criminal proceeding[]," DE 290 at 2, presumably not covered by a statute of limitations applicable to a "civil action commences against the United States." 28 U.S.C. § 2401(a). Even more surprising to us was your Office's failure to discuss the second sentence in § 2401(a), which provides that the si

ding royalty, politicians, businessmen, and professional and personal acquaintances. Complaint, Jane Doe No. 102 v. Epstein, No. 9:09-CV-80656- KAM (S.D. Ha. May 1, 2009). 3. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Investigation opened an investigation into all

GRAND JURY PROCEEDINGS SEALED ORDER GRANTING APPLICATION FOR PERMISSION TO DISCLOSE GRAND JURY MATERIAL THIS MATTER has come before the Court on the United States' Sealed Application for Permission to Disclose Grand Jury Material and for Entry of a Protective Order. The Court has considered the Motion and find

ion with an administrative proceeding conducted by the Justice Department's Office of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of Jane Doe I and Jane Doe 2 United States, S.D. Ha. Case No. 08-80736-Civ-Marra; (3) the materials

ibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of Jane Doe I and Jane Doe 2 United States, S.D. Ha. Case No. 08-80736-Civ-Marra; (3) the materials are needed to avoid an injustice in another proceeding, that is, the OPR administrative proceeding

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal injury as a result of such violation may sue in any appropriate United States District Court and shall recover the actual damages such minor sustains and the cost of the suit, including a reasonable attorney's fee. Any minor a

pstein, 2009 WL 383332 (S.D. Fla. Feb. 12, 2009); Doe No. 31. Epstein 2009 WL 383330 (S.D. Fla. Feb. 12, 2009); Doe No. 41. Epstein, 2009 WL 383286 (S.D. Ha. Feb. 12, 2009); and Doe No. 5I. Epstein, 2009 WI, 383383 (S.D. Fla. Feb. 12, 2009); see also U.S. Scheidt, Slip Copy, 2010 WL 144837, fn. 1 (E.D.

luding alleged victims), which would necessarily thwart such individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. &2e generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in ones sexual matters and is not limi

Doe v. Epstein 08-CV80119 Page No. 26 also Fed.R.Civ.P. 26(b)(1) and Fla. Stat. 768.72; Gallina v. Commerce And Industry, Ins., 2008 WL 3895918 (S.D. Ha. 2009)(unless liability for punitive damages is established at trial, the discovery sought is not relevant). In Gallina, the court held that in lig

M Document 414 Entered on FLSD Docket 08/11/2017 Page 4 of 11 examination on matters reasonably related to those brought out in direct examination." United States v. Nobles, 422 U.S. 225, 239-40 (1975) (footnote omitted). The same considerations apply when considering any assertion of attorney-client privileg

pposing party's case while simultaneously brandishing it as a shield from disclosure of any Achilles heels." Stern v. O'Quinn, 253 F.R.D. 663, 677 (S.D. Ha. 2008). CONCLUSION The Court should direct the Government to produce to the victims all documents that it previously withheld based on work-produc

nsure oldie residency of defendant JEFFREY ESPSTON, because he hat residences in New York, Florida, Ncw Mexico, and also outside of the continental United Slates. 4. The defendant, ella was a resident of Florida. 13440 This tax was received by GM FAXMakes fax server. For more information, visit httpfiwww.

rement of complete diversity. (a) Plaintiff= is a citizen of Florida. (Compl. ¶ 2.) 3 See Jane Doe No. 2 v. Jeffrey Epstein, No. 08-CV-80119-KAM (S.D. Ha. filed Feb. 6, 2008); Jane Doe No. 3 v. Jeffrey Epstein, No. 08-CV-80232-KAM (S.D. Ha. filed Mar. 5, 2008); Jane Doe No. 4 v. Jeffrey Epstein, No.

, no attorney has entered an appearance on behalf of the Defendant. 4. The Defendant, Jeffrey Epstein is not on active duty in the armed forces of the United States. See Exhibit "B". 5. Accordingly, pursuant to Federal Rule of Civil Procedure 55(a), Plaintiff applies to this Honorable Court for the entry of de

AGAINST DEFENDANT Plaintiff, Jane Doe No. 3, by and through her undersigned counsel, and pursuant to the Federal Rule of Civil Procedure 55(a) and S.D. Ha. L.R. 7.1, hereby files this Motion for Entry of Default Against Defendant, and states as follows: 1. On May 7, 2008. Defendant Jeffrey Epstein wa