Epstein Secrets

22(b) Not Consummated Showed up for meeting Sting 69 EFTA00224203 VCOURT CASES FACILITY FACTS/COMMUNICATION CHARGE itn N.D. Tex. U.S. I Jackson, 2002 U.S. Dist. LEXIS 6168/N.D. Tex. 2002); see U.S. I Jackson, 2002 U.S. LEXIS 539 (N.D. Tex. 2002) for details of facts; and U.S. I. Jackson

); underlying case U.S. I Gawk, Case No. 5- 05-MJ-341 (N.D.N.Y. 2005) Telephone Mayor solicited

conduct evidentiary hearing. 2422(b); 2423 Not Consummated Showed up for meeting Sting E.D. Cal. U.S. I Carter, 2006 U.S. Dist. LEXIS 22501 (E.D. Cal. 2006) Internet Internet chat room "preteen parents who share"; defendant wants to have sex with daughter while mother watches; Internet email &

d without bond. 2422(b) Not Consummated Sting 74 EFTA00226322 COURT CASES . FACILI TY . FACTS/COMMUNICATS: CHARGWRiii ., D. Neb. U.S. I Jackson, 2007 U.S. Dist. LEXIS 33639 (D. Neb. 2007) *State Conspiracy charge dropped, no federal conspiracy Internet Internet chats with "14 yr-old";

); underlying case U.S. Gosek, Case No. 5- 05-MJ-341 (N.D.N.Y. I 2005) Telephone Mayor solicit

conduct evidentiary hearing. 2422(b); 2423 Not Consummated Showed up for meeting Sting E.D. Cal. U.S. I Carter, 2006 U.S. Dist. LEXIS 22501 (E.D. Cal. 2006) Internet Internet chat room "preteen parents who share"; defendant wants to have sex with daughter while mother watches; Internet email &

ocument 15 Entered on FLSD Docket 11/11/2010 Page 3 of 16 CASE NO: 08-CV-80119-NIARRA/JOHNSON and to Order Epstein to immediately file an Answer to MJ's Complaint or alternatively to Strike Epstein's pleadings. FACTUAL BACKGROUND At any hearing the Court might conduct, M.J. is prepared to establi

e court must then "weigh and determine (the) disputed issues of facts on a Rule 12(b)(5) motion." Cranford v. United States, 359 F.Supp.2d 981, 984 (E.D. Cal. 2005). An evidentiary hearing is the proper vehicle for resolving this particular factual dispute. See Blair v. City of Worcester, 522 F.3d 105, 1

Page 9 of 16 a criminal prosecution. Carson v. Jackson, 466 So.2d 1188, 1190 (Fla. 4th DCA 1985) (analyz

purely procedural in nature and does not create a federal physician-patient or hospital-patient privilege." Allen v. Woodford 2007 WL 309485 *I I (E.D. Cal. 2007). Under HIPAA, health care information may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing

, Fla. Stat.2 (¶'s Motion, p. 8-9). See Carson v. Jackson, 466 So.2d 1188, 1192 (Fla. 4th DCA 1985); and D

(Health Insurance Portability and Accountability Act) objection, as noted in the case cited in Plaintiffs motion Allen v. Woodford, 2007 WL 309485 (E.D. Cal. 2007), (p. 9), HIPPA institutes procedural safeguards to protect the privacy of an individual's medical information and history. In the context of

Page 9 of 16 a criminal prosecution. Carson v. Jackson, 466 So.2d 1188, 1190 (Fla. 4th DCA 1985) (analyz

purely procedural in nature and does not create a federal physician-patient or hospital-patient privilege." Allen v. Woodford 2007 WL 309485 *I I (E.D. Cal. 2007). Under HIPAA, health care information may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing

F.3d 1281 (11th Cir. 2004) (RICO conspiracy); U.S. v. Hornaday, 392 F.3d 1306 (11" Cir. 2004) (conspiracy charge was error); EFTA01729485 U.S. v. Jackson, 2007 U.S. Dist. LEXIS 33639 (D. Neb. 2007) (state conspiracy charge dropped because no conspiracy possible with undercover agent); U.S. v. Bianchi,

uct evidentiary hearing. 2422(b); 2423 Not Consummated Showed up for meeting Sting G.D. Cal. • U.S. v. Carter, 2006 U.S. Dist. LEXIS 22501 (E.D. Cal. 2006) . Internet Internet chat room "preteen parents who share"; defendant wants to have sex with daughter while mother watches; Internet emai

F.3d 1281 (11th Cir. 2004) (RICO conspiracy); U.S. v. Hornaday, 392 F.3d 1306 (11`" Cir. 2004) (conspiracy charge was error); EFTA00079414 U.S. v. Jackson. 2007 U.S. Dist. LEXIS 33639 (D. Neb. 2007) (state conspiracy charge dropped because no conspiracy possible with undercover agent); U.S. v. Bianchi,

onduct evidentiary hearing. 2422(b); 2423 Not Consummated Showed up for meeting Sting E.D. Cal. U.S. v. Carter, 2006 U.S. Dist. LEXIS 22501 (E.D. Cal. 2006) Internet Internet chat room "preteen parents who share"; defendant wants to have sex with daughter while mother watches; Internet email &