Epstein Secrets

motion to limit the examination to 6 hours, Defendant’s citation to Lahr v. Fullbright & Jaworski, LLP , 164 F.R.D. 196, 202-204 (N.D. Texas 1995), Morton v. Haskell Co., No. 94-976-Civ-J-20, 1995 WL 819182 (N.D. Fla. September 12, 1995) and Mann v. Newport Tankers Corp., 96 F.R.D. 31 (S.D.N.Y. 1982)

ed. In Lahr, the court declined to limit a three hour clinical intake and evaluation by the defendant’s psychologist. Lahr, 164 F.R.D. at 201. In Morton, the court declined to limit a defense psychologist’s evaluation to one hour and declined to limit the evaluation to cover only one specific year,

CASE NO.: 08-CV-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN,

court restrict same in time or scope. Lahr v. Fullbright & Jaworski, LLP., 164 F.R.D 196, 202-204 (N.D. Texas 1995)(refusing to limit examination); Morton v. Haskell Co., No. 94-976-CIV-J-20, 1995 WL 819182, at *3 (N.D.Fla. Sept.12, 1995) (declining to limit duration of examination); See also Affidavi

dens, FL 33410 561-684-6500 Fax: 561-515-2610 Counsel for Plaintiff in Related Case No. 08-08804 [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidrogarcia@b

re silly, unfounded and alleged violations which are not defined as violations under the NPA but arrived at by the USAO. Thus, EPSTEIN is left with "Morton's Fork" in his side - the undesirable choice of taking the 5th Amendment and having a judgment (summary or otherwise) entered against him in the ci

scayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ahorowitzehermanlaw.com Iriveraahermanlaw.com Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300

zen Eleventh Circuit cases that include a prosecutio under §2422(b), most of which involve the prototypical fact pattern. See, e.g., United States'. Morton, 364 F.3d 1300 (I I* Cir. 2004), judgment vacated for Booker consideration, 115 S. Ct. 1338 (2006); United Stalest Grego, 363 F.3d 1093 (II* Cir. 2

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

zen Eleventh Circuit cases involving prosecutions under § 2422(b), most of which involve this prototypical fact pattern. See, e.g„ United States v. Morton. 364 F3d 1300 (11th Cir. 2004), vacated for further consideration in light stf Booker, 125 S. Ct. 1338 (2006), opinion reinstated by, 144 Fed. Appx.

a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to (6) In or around 2002, Defendant JEFFREY EPSTEIN paid $400 to Jane Doe #2, who was then fifteen years' old, to (7) In or around 2002, Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she had any younger friends who woul

re silly, unfounded and alleged violations which are not defined as violations under the NPA but arrived at by the USAO. Thus, EPSTEIN is left with "Morton's Fork" in his side - the undesirable choice of taking the 5th Amendment and having a judgment (summary or otherwise) entered against him in the ci

day of March, 2009. Adam D. Horowitz, Esq. Jack Alan Goldberger Stuart S. Mermelstein Es• Atterbu Goldberger & Weiss P.A. Counsel for Plaintiff Jane Doe #2 ounse or 'e en ant Je rey o- Epstein 14 EFTA00067396 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Page 15 of 15

n Eleventh Circuit cases that include a prosecution under §2422(b), most of which involve the prototypical fact pattern. See, e.g., United States v. Morton, 364 F.3d 1300 (I Is Cir. 2004),judgment vacated for Booker consideration, 125 S. Ct. 1338 (2006); United States v. Orrega, 363 F.3d 1093 (11th Cir

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in Prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

n Eleventh Circuit cases that include a prosecution under §2422(b), most of which involve the prototypical fact pattern. See, e.g., United States v. Morton, 364 F.3d 1300 (11th Cir. 2004),judgment varied for Booker consideration, 125 S. Ct. 1338 (2006); United States v. Orrega, 363 F.3d 1093 (11th Cir.

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doc to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

include a prosecution under Garrett, 190 3d 1220 (116 Cir. §2424(b), most of which involve the prototypical fact pattern. See, e.g., United States !Morton, 364 I3d 1300 (I l ° Cij. 2004),judgnwru vacated for Booker consideration, 125 S. Ct. 338 006); United States I Orrega, 363 I3d 1093 (116 Cir. 2004

there, in facts far different from those presented here, the defendant admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones