* Case 9:08-cv-80119-KAM
Summary
* Case 9:08-cv-80119-KAM Document 57-4 Entered on FLSD Docket 03/02/2009 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, I. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS TO SECOND REQUEST FOR PRODUCTION, dated December 19, 2008 Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, serves his responses and objections to the Request to Produce, dated December 19, 2008 and states: Request No. 1. All policies of insurance, including the declarations page and all binders, amendments, and endorsements, covering Defendant's residence at 358 El Brillo Way, Palm Beach, FL 33480. Response: Objection, overly broad, not relevant and material and not calculated to lead to the discovery of admissible evidence. Plaintiff alleged claims occurred during a specific time period in 2004 - 2005, yet to be specifically identified. Yet, no time period wh
Persons Referenced (4)
“...man, Esq. Stuart S. Mermelstein, Esq. Miami FL 33160 Fax: ounse or laintiff Jane Doe #2 Jack Alan Goldberger , P.A. West Palm Beach, FL 33401-5012 Fax: uo-uounsei tor tietendant Jeffrey Epst...”
Stuart S. Mermelstein“...th day of January, 2009. Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. Miami FL 33160 Fax: ounse or laintiff Jane Doe #2 Jack Alan Goldberger , P.A. West Pal...”
Jeffrey Epstein“... FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, I. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS TO SECOND REQUEST FOR PRODUCTION, dated...”
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Case 9:08-cv-80119-KAM
Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant, Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing this action for a time certain (i.e., until late 2010 when the NPA expires), pursuant to the application of the Fifth Amendment of the U.S. Constitution and the fact that a parallel proceeding is ongoing and being investigated. In support of his motion, EPSTEIN states: I. Introduction At the outset, EPSTEIN notes this Court's prior Order, (DE 33), in which this Court denied a motion for stay brought by Def
Case 9:08-cv-80119-KAM
Case 9:08-cv-80119-KAM Document 35 Entered on FLSD Docket 08/0612008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JOINT MOTION TO APPROVE STIPULATION FOR ACCEPTANCE OF SERVICE OF PROCESS AND AGREED DATE FOR DEFENDANT'S RESPONSES TO COMPLAINTS EFTA00222397 Case 9:08-cv-80119-KAM Document 35 Entered on FLSD Docket 08(0612008 Page 2 of 2 Plaintiffs, Jane Doe 2, Jane Doe 3, Jane Doe 4 and Jane Doe 5, and Defendant Jeffrey Epstein, file this Joint Motion for Approval of Stipulation of Acceptance of Service of Process and Agreed Date for Defendant's Respo
Case 9:08-cv-80119-KAM
Case 9:08-cv-80119-KAM Document 69 Entered on FLSD Docket 04/02/2009 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files his Answer to the Second Amended Complaint and states: 1. Without knowledge and deny. 2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 41h DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth Amendment - "[fit would be incongruous to have different standards determine the validity of a claim of privilege ba
Case 9:08-cv-80119-KAM
Case 9:08-cv-80119-KAM Document 148 Entered on FLSD Docket 06/09/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S UNOPPOSED FIRST MOTION TO AMEND AFFIRMATIVE DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, moves to amend his affirmative defenses as set forth in the attached Defendant EPSTEIN's First Amended Answer & Affirmative Defenses to Plaintiff's Second Amended Complaint, attached hereto as Exhibit A. Rule 15(a), Fed.R.Civ.P. (2009); Loc. Gen. Rules 7.1, 15.1 (S.D. Fla. 2009): 1. Pursuant to Rule 15(a)(2), Fed.R.Civ.P., a party may amend his pleading "only with the opposing party's written consent or the court's leave. The court should freely give leave when justice so requires." Plaintiff's counsel has consented in writing to D
Case 9:08-cv-80119-KAM
Case 9:08-cv-80119-KAM Document 66-3 Entered on FLSD Docket 03/26/2009 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. 11+ 1 DOCKET NOTICE OF TAKING DEPOSITION VIA VIDEO PLEASE TAKE NOTICE that the undersigned attorney will take the deposition via video of: DEPONENT DATE & TIME LOCATION OF DEPOSITION Jane Doe #3 Tuesday, U.S. Legal Support do Stuart Mermelstein, Esq. April 14, 2008 444 West Railroad Avenue 18205 Biscayne Boulevard 9:00 a.m. Suite 300 Suite 2218 West Palm Beach, FL 33401 Miami, FL 33160 Phone: 561 835-0220 upon oral examination, before U.S. Legal Support, a Notary Public, or any other officer authorized by law to take depositions in the State of Florida. The oral examination is being taken for the purpose of discovery, for use at trial, or for s ch other purposes as are permitted under the applicable Statutes of Rules of
Case 9:08-cv-80119-KAM
Case 9:08-cv-80119-KAM Document 50 Entered on FLSD Docket 11/10/2008 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION TO DISMISS & FOR MORE DEFINITE STATEMENT Defendant, JEFFERY EPSTEIN, (EPSTEIN), by and through his undersigned attorneys, files his reply to Plaintiffs' Memorandum Of Law In Opposition To Motions To Dismiss, dated October 31, 2008, and states: Although Plaintiffs, Jane Doe Nos. 2 through 7, are separate and distinct persons, in separate and distinct actions, with separate and distinct facts and circumstances pertaining to the claims each is attempting to allege, Plaintiffs' counsel has filed a broad brush, identical response to Defendant's motions to dismiss and for more definite statement which were filed in each of the actions. As pointed out in Defendant's previo
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