Epstein Secrets

OU PROPERTIES II LLC WALKER,NANCY G CALLAWAY,BRENDA T RAQUET,WALTER F OCEAN GRAN

QUINN,OLIVER H LOCKER,NANCY OWEN,JANE D CUSHMAN & WAKEFIELD KELLER,MICHAEL

wards 3 directly from the Fourth Diatrict Court of Appeal, 4 has asked about and answered that are on this 4 RJ Reynolds Tobacco Company versus Calloway, and it s privilege log. There's over a hundred of then. 5 talks about the trial judge's ultimate 4 So this disk is not a di➢k of their privil

RE II Deoksbor 5th and nide it clear to all parties that 10 12 exhibits that. here net disclosed by the end of II For Non-Parties L.M., E.M. 4 Jana Doe 22 1a Deoabor -- and I think it nay have been the 14 De her 22 dace -- I'm not sure about that exact 13 la date -- but exhibits that were no

wards 3 directly from the Fourth Diatrict Court of Appeal, 4 has asked about and answered that are on this 4 RJ Reynolds Tobacco Company versus Calloway, and it s privilege log. There's over a hundred of then. 5 talks about the trial judge's ultimate 4 So this disk is not a di➢k of their privil

question in front of you sight now is • very brief, representing three victims; LH, EM and • what to do about this. Well, we knee one thing. • Jane Doe. /Vat ono housekeeping natter. s lie know there's been absolutely no waiver of 10 No have riled a notion to intervene, which is 10 attorney/cl

em. • presentation. I often refer to a case that I printed directly from the Fourth District Court of Appeal, RJ Reynolds Tobacco Company versus Calloway, and it talks about the trial judge's ultimate So this disk is not a disk of their privileged docunents. It's a disk of 27,500 documents. And wha

oulevard West Palm Beach, FL 33409 By JACK SCAROLA, ESQUIRE By DAVID P. VITALE JR., ESQUIRE By KAREN TERRY, ESQUIRE For Non-Parties L.N., E.M. 4 Jane Doe HATCH, JAMES 4 DODGE, P.C. 10 Nest Broadway, Suite 400 Salt Lake City, UT 84101 By PAUL G. CASSELL, ESQUIRE 5 For Jeffrey Epstein: 4 ATTERBUR

rshowitz for sexual purposes. Numerous courts have declined to allow a mere "reputational" interest to justify mandatory intervention. For example, Calloway" Westinghouse Eke. Cop., 115 F.R.D. 73 (M.D. Ga. 1987), denied a motion to intervene where the alleged interest was a doctor's "own reputation and

court in Doe'. Epstein, No. 9:08- cv-80I19-KAM (S.D. Fla.). Brunel's attorney asked counsel for Jane Doe to postpone the scheduled deposition date. Jane Doe's counsel agreed, and then Brunel's attorney cancelled the rescheduled deposition date. Brunel's counsel represented that Brunel was outside the count

sations about Prof. Dershowitz until a month ago, even though the alleged transgressions supposedly occurred some fifteen years ago. Although neither Jane Doe #3 nor anyone else had previously asserted any improper sexual contact with Prof. Dershowitz, now Jane Doe #3 cynically exploits the yoke of victimhoo

o the Court, Jane Doe #3’s Response takes remarkable liberties in describing what is claimed to be the law to Court. For example, the Response quotes Calloway v. Westinghouse Elec. Corp., 115 F.R.D. 73, 74 (M.D. Ga. 1987) for the proposition that “a witness’ interest in his reputation alone . . . does not c