5
Shared Docs
5
Same-Page
5 / 7
Mentions
. R. Crim, P. 11(f) and 410: "to encourage non- litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d 1072, 1074 (11th Cir. 1976). ee ug. Stockman v. Oakcrest Dental Center P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose underlying Rule 408 . . . is the promotion of the public policy favor
Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 4 of 37 Doe v. Epstein 08-CV80119 Page No. 4 (a) Jane Doe Plaintiff, Jane Doe's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth therein are incorporated
e, if this court rules that any of the information requested herein should be produced (e.g., Requests Numbers 12 and 13 (tax returns and passport — Jane Doe) and Request Number 1 (tax returns-Jane Doe 2-8)), it shall only do so after an in camera hearing allowing the documents to be reviewed and placed o
27, 2010 from Michelle Stockman of Agence France Presse. (Exhibit E attached). Agence France Presse is a newswire service with a world- wide reach. Stockman wanted to meet with Plaintiff Brunel to arrange a model shoot with MC2. However, due to the adverse publicity surrounding Plaintiffs as a result of
hat appears to be personal numbers," the court papers say. Allegations in the documents say Epstein threatened victims — including Edwards' client Jane Doe — despite no-contact orders in effect. Epstein had Doe tailed by a private investigator as her trial date neared, the court filings say. One time,
the Southern District of Florida accepted Epstein's case for prosecution, and the FBI issued victim notification letters to my two clients. minors Jane Doc No. I and Jane Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the prosecutors and Epstein. On Sept. 24, 2007, the pr
Crim, P. 11 (f) and 410: "to encourage non- litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d 1072, 1074 (11th Cir. 1976). See, Lls·, Stockman v. Oakcrest Dental Center, P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose underlying Rule 408 ... is the promotion of the public policy favori
ocket entries. Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 4 of 37 Doe v. Epstein 08-CV80119 Page No. 4 (a) Jane Doe Plaintiff, Jane Doe's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth t
lying Rules 11(f) and 410: "to encourage non-litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d ion, 1074 (11th Cir. 1976). Zes, zgr. Stockman v. Oakcrest Dental Center, P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose underlying Rule 408 . . . is the promotion of the public policy favo
des Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. §2255, one of the principal causes of action in the Jane Doe cases. This opinion work product should not be disclosed when it was incorporated into heartland plea negotiations that are accorded protection und
t 27, 2010 from Michelle Stockman of Agence France Presse. (Exhibit E attached). Agence France Presse is a newswire service with a world- wide reach. Stockman wanted to meet with Plaintiff Brunel to arrange a model shoot with MC2. However, due to the adverse publicity surrounding Plaintiffs as a result of E
r the Southern District of Florida accepted Epstein’s case for prosecution, and the FBI] issued victim notification letters to my two clients, minors Jane Doe No. | and Jane Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the prosecutors and Epstein. On Sept. 24, 2007, the pro
Entities connected to both Stockman and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Salt Lake City
LOCATION
Alexander Acosta
PERSONScott Rothstein
PERSONRobert C. Josefsberg
PERSON
Department of Justice
ORGANIZATION