Epstein Secrets

R. 26.1 K (also found in Fed. R. Civ. P. 30(d)), Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (

______ __:! EPSTEIN'S RESPONSE IN OPPOSITION TO JANE DOE'S MOTIONS FOR PROTECTIVE ORDER BARRING SECOND DEPO

scheduled for November 13, 2009. Nevertheless, as Jane Doe's deposition will most likely occur during the we

ble under the circumstances and result in prejudice to Epstein by denying him the opportunity to obtain discovery that is central to his defense. See Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D. W.Va. 2009)(granting the defendant an additional one day of 7 hours to depose the plaintiff, rea

656, 09-80802, 09-81092 ____________________________________/ OMNIBUS ORDER THIS CAUSE is before the Court on the following motions: (1) Plaintiff’ Jane Doe’s Motion for Protective Order Barring Second Deposition and for Sanctions (D.E. #378); and, (2) Plaintiff Jane Doe No. 4's Motion for Protective Order

n’s Motion to Compel (D.E. #s 67 & 68), which sought information related to Plaintiff’s past sexual history. All agree that there were instances at Jane Doe 4's initial deposition where she was instructed by her counsel not to answer questions “relat[ed] to sexual partners’ names or sexual positions.” Jane

ain discovery that is central to his defense. See Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S

This is based on Plaintiffs’ representation that Jane Doe’s deposition lasted 8 hours. 2 3 is necessary for a

ne Doe No. 4's deposition. 15. Although the Court waived the seven hour time limit in S.D. Fla. L.R. 26.1 K (also found in Fed. R. Civ. P. 30(d)), Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D.W.Va. 2009) is illustrative and supports Epstein's request for additional time to depose Plaint

1,08-80994, 08-80993, 08-8081 I, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 _______________ / EPSTEIN'S RESPONSE IN OPPOSITION TO JANE DOE NO. 4'8 MOTION FOR PROTECTIVE ORDER AGAINST SECOND DAY OF DEPOSITION OF PLAINTIFF EXTENDING PAST SEVEN HOURS IN THE AGGREGATE Defendant, JEFFREY E

Federal Government, with the final contract for a South Australian build awarded to French company DCNS with majority of the work to take place in Osborne, South Australia-1351 Following the announcement, Jay Weatherill travelled to France to meet with DCNS and others in an attempt to maximise opportun

14) C)(4 R L tql3Q•sC at egejt-ttiV POS I C. t\CS A December 3o, 2014, federal civil suit was filed in Florida by Jane Doe i (Courtney Wild) and Jane Doe 2 against the United States for violations of the Crime Victims', Rights Act by the U.S. of Justice's NPA with Epstein and his limited 2008 state plea.

Federal Government, with the final contract for a South Australian build awarded to French company DCNS with majority of the work to take place in Osborne, South Australia.f35-1 Following the announcement, Jay Weatherill travelled to France to meet with DCNS and others in. an attempt to maximise opport

s v. United States (2014) 50' 43 e L ecsosE tRA1`19.... PROs-i NENS1 PCS a I ChX.3 A December 3o, 2014, federal civil suit was filed in Florida by Jane Doe 1 (Courtney Wild) and Jane Doe 2 against the United States for violations of the Crime Victims' Rights Act by the U.S. Department of Justice's NPA w

rs look beyond such documents to examine the defendant's il proven relevant conduct. Nichols, 1 F.3d at 1271; seeU.S.S.G. § 1B1.3; United States Osborne, I F.3d 434, 438 (8th Cir.1999); nited States Marqurlo, 149 F.3d 36, 45 (1st Cir.1998); United States Clay, 117 F.3d 317, 319-20 (6th Cir.1997)

s. To inform Jane Doe of dates that he had arranged, Evans called Jane Doe on a cellular telephone that she had acquired from him. Evans also gave Jane Doe's cellular telephone number to customers and told Jane Doe to arrange dates when customers called. During the dates, Ev- ans called Jane Doe on the