Epstein Secrets

h undersigned counsel, hereby files this emergency motion for a hearing and for an immediate finding that Epstein stands in civil contempt of Judge Marra's order forbidding indirect contact with Jane Doe and Judge Palermo's order forbidding harassment of Jane Doe. Jane Doe asks for this Court for reme

finding that Epstein stands in civil contempt of Judge Marra's order forbidding indirect contact with Jane Doe

er home (or, if necessary, other place of safety) without facing the threat of any further harassment or intimidation. See Serra Chevrolet, Inc. v. General Motors Corp., 446 F.3d 1137, 1147 (11th Cir. 2006) ("Civil contempt may be imposed in an ordinary civil proceeding upon notice and an opportunity to be heard.")

h Amendment right not to do so. "Stonewalling and delaying," Horowitz said. "I'm not surprised." Horowitz said he has asked US. District Judge Kenneth Marra to order Epstein to turn over the information. A local attorney for Epstein, Jack Goldberger, did not respond to a re- quest seeking comment. E

isclosure will be ordered." Seeking to keep the agreement sealed, Assistant U.S. Attorney argued that the agreement is not part of any case before Marra. "The non-prosecution agreement has never been filed under seal in federal court," he wrote. He also denied that the agreement has been inaccuratel

ere 34 percent lower than a year ago. "Stimulating sales is the only way to get the auto industry back on its led," said Rep. Donald Manzullo, General Motors Corp. and Chrysler LLC have received billions of dol- lars in government aid and the entire auto indus- try has watched car sales plummet during the pa

1 Jane Doe No. 2 v. Epstein Case No. 08-CV-80119-Marra-Johnson Page 2 in multiple civil actions assert

e legal consequences of their actions. FNl8. See General Motors Corp. v. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105, 11

UTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY

settled that a Defendant may take the deposition of a ma and/or a witty-cc before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and lave v. General Motors Corp., 43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2-7 commenced separate civil actions upon the filing of same against Jeffrey Epstein. Therefore, Def

THERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEI

ts or representatives of a party's attorney. 12. The attorney-client privilege also extends to subordinates of a party's attorney. See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege