brief in opposition to Jeffrey Epstein's motion for summary judgment dismissing the federal claims in this action ("Si °pp.') may be found on PACER, S.D. Ma. Civil Docket for Jane Doe v. Jeffro Epstein, Case # 9:08-cv-80893-KAM ("Dockerp, ppeP4 EFTA00207294 expressions of confidence in the strength o

ychological and emotional damages" and loss of self-esteem and dignity as referenced above). Cherenfant v. Nationwide Credit, Inc. 2004 WL 5315889 (S.D. Ma. 2004)(order allowing discovery of medical records consistent with Plaintiff's allegations in complaint). This too goes directly to Plaintiffs dama

brief in opposition to Jeffrey Epstein's motion for summary judgment dismissing the federal claims in this action ("Si °pp.') may be found on PACER, S.D. Ma. Civil Docket for Jane Doe v. Jeffro Epstein, Case # 9:08-cv-80893-KAM ("Dockerp, ppeP4 EFTA00612027 expressions of confidence in the strength o

Federal Criminal Action.' In these lawsuits, even before civil discovery begins, under the Initial Disclosures required by Fed. R. Civ. P. 26 and S.D. Ma. Local Rule 26.1, Epstein "must" disclose the identities of all the witnesses he would call in his defense to the Federal Criminal Action (Rule 26(a