Epstein Secrets

igh rates of recidivism. According to a source in law enforcement, however, Epstein was allowed to submit a report by his private psychologist, Dr. Stephen Alexander of Palm Beach, Florida, whose phone has since been disconnected with no forwarding information. The Daily Beast's second article provided details a

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

2 and 13); and Epstein’s medical records from Dr. Stephen Alexander (Request 16). Each of these categories of reques

prosecution. In each of these motions Plaintiff Jane Doe seeks to compel answers to certain requests for a

d be unreasonable, and would therefore violate the Constitution; overly broad. Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my a

the convenience of the court – and in compliance with Local Rule 26.1 H (party filing motion to compel shall list specific requests in succession) – Jane Doe’s requests for production and Epstein’s objections are as follows: Request No. 1: Copies of all telephone records in your or your attorney’s possess

ntiffs request for Epstein's medical records, Dr. Stephen Alexander was hired as au expert consultant by Epstein's a

EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE, MOTION TO COMPEL RESPONSE TO PLAINTIFF'S REQUES

d be unreasonable, and would therefore violate the Constitution; overly broad. Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my a

the convenience of the court – and in compliance with Local Rule 26.1 H (party filing motion to compel shall list specific requests in succession) – Jane Doe’s requests for production and Epstein’s objections are as follows: Request No. 1: Copies of all telephone records in your or your attorney’s possess

All medical records of Defendant Epstein from Dr. Stephan Alexander. Defendant is asserting his U.S. constitutiona

not require any mind to pick and choose. Indeed, Jane Doe’s request is significantly narrower that other req

from the date hereof to provide the discovery subject to these Requests. The last category of documents concern Epstein's medical records from Dr. Stephen Alexander (Request 16). Epstein raises several objections to this category of Requests from relevancy concerns to privilege claims. Because Plaintiff has fail

e entered into a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution. In each of these motions Plaintiff Jane Doe seeks to compel answers to certain requests for admissions, interrogatories and requests for production that were propounded on Defendant Epstein.

fice or any agents thereof). 12. All medical records of Defendant Epstein from any psychologist or psychiatrist, including but not limited to Dr. Stephan Alexander or any court appointed doctor. 13. All medical records from any other doctor who has treated Defendant Epstein for sexual issues or who has provid

y to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages as specifically allowed by this and other stat

from the date hereof to provide the discovery subject to these Requests. The last category of documents concern Epstein's medical records from Dr. Stephen Alexander (Request 16). Epstein raises several objections to this category of Requests from relevancy concerns to privilege claims. Because Plaintiff has fail

e entered into a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution. In each of these motions Plaintiff Jane Doe seeks to compel answers to certain requests for admissions, interrogatories and requests for production that were propounded on Defendant Epstein.

high rates of recidivism. According to a source in law enforcement, however, Epstein was allowed to submit a report by his private psychologist, Dr. Stephen Alexander of Palm Beach, Florida, whose phone has since been disconnected with no forwarding information. The Daily Beast’s second article provided details ab

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