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Case 9:08-cv-80736-KAM Document 357 Entered on FLSD Docket 01/29/2016 Page 1 of 4

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Case 9:08-cv-80736-KAM Document 357 Entered on FLSD Docket 01/29/2016 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE NO. 1 AND JANE DOE NO. 2'S MOTION TO TEMPORARILY SEAL THEIR REPLY IN SUPPORT OF MOTION TO COMPEL ANSWERS TO SUPPLEMENTAL REQUESTS FOR ADMISSION AND REQUESTS FOR PRODUCTION COME NOW Jane Doe No. 1 and Jane Doe No. 2 (the "victims"), by and through undersigned counsel, to file this motion to temporarily seal their reply in support of their motion to compel the Government either to provide answers to certain requests for admission and requests for production involving Epstein lawyer Alan Dershowitz or, in the alternative, to properly assert privilege over these discovery requests. 1. On December 28, 2015, Jane Doe 1 and Jane Doe No. 2 filed their motion to temporarily seal their motion to compel answers to supplemental requests for admissions and requests for production. D.E. 347. Petitioners then filed, under seal, their motion to compel answers. 2. On January 14, 2015, respondent filed its opposition to petitioners' motion to compel answers to supplemental requests for admission and requests for production under seal. 3. Since the motion involves a non-party, respondent requests that it be allowed to file it under seal, pending this Court's resolution of the petitioners' motion to temporarily seal. 1 EFTA01091399 Case 9:08-cv-80736-KAM Document 357 Entered on FLSD Docket 01/29/2016 Page 2 of 4 WHEREFORE, the victims request that their Reply in Support of their Motion to Compel be placed under seal for ten days or until the Court has ruled on any motion by any non-party to seal the motion, whichever is longer. DATED: January 29, 2016 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone Facsimile E-mail: And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah` 332 S. 1400 E. Salt Lake City, UT 84112 Attorneys for Jane Does No. 1, Z 3 and 4 `This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah 2 EFTA01091400 Case 9:08-cv-80736-KAM Document 357 Entered on FLSD Docket 01/29/2016 Page 3 of 4 CERTIFICATE OF SERVICE I certify that the foregoing document was served on January 29, 2016, on the following using the Court's CM/ECF system or, for non-parties, by separate email service: Dexter Lee A. Marie Villafafia Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Kornspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 Attorneys for Jeffrey Epstein Kendall Coffey, Fla. Bar No. 259681 Gabriel Groisman, Fla. Bar No. 25644 Ben. amin H. Brodsky. Fla. Bar No. 73748 COFFEY BURLINGTON, 2601 South Bayshore Drive, PHI Miami, Fl Telephon Facsimile: Thomas E. co , r. Cole Scott & Kissane 3 EFTA01091401 Case 9:08-cv-80736-KAM Document 357 Entered on FLSD Docket 01/29/2016 Page 4 of 4 Dadeland Centre II Suite 1400 9150 S Dadeland Boulevard Miami, FL 33156 Email: Attorneys for Alan Dershowitz Is/ Bradley J. Edwards 4 EFTA01091402

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Case #9:08-CV-80736-KAM

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Dershowitz Supplement to Motion for Limited Intervention

Case 9:08-cv-80736-KAM Document 285 Entered on FLSD Docket 01/12/2015 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOES #2 Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. ________________________________/ ALAN DERSHOWITZ’S SUPPLEMENT TO HIS MOTION FOR LIMITED INTERVENTION (DE 282) Alan M. Dershowitz, a nonparty to this litigation, respectfully supplements his previously filed Motion for Limited Intervention (

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5(19/22, 3:52 PM SEA At. "250SC. fktmct JcereY Epsteh - Wildpedla Epstein a massage". She claims she was taken to his mansion, where he exposed himself and had sexual intercourse with her, and paid her $200 immediately afterward.1io61 A similar $50-million suit was filed in March 2008, by a different woman, who was represented by the same lawyer.E•g-91 These and several similar lawsuits were dismissed.1139-) All other lawsuits have been settled by Epstein out of court' ll Epstein made many art-pl-atirt r s_ettlements with alleged victims.W23 - - - _ E_XCAt "-Vet 5sE RItACt PnOi- CiOR °NICER • - 40L'aritfrieerPROS1 1701-i0.Ni o> SIE•us) i1/44".,e036( C ; Perversion of Justice, Miami Herald, November 30, 2018. Victims' rights: Jane Does v. United States (2014)*SC7ck%A L. ne,OSC Rt p Rom N)Eiszci poS IT c"),3 A December 3o, 2014, federal civil suit was filed in Florida by Jane Doe 1 ([REDACTED - Survivor]) and Jane Doe 2 against the United States for violations of the Crime Vi

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STATEMENT BY ALAN DERSHOWITZ

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Epstein Depositions

10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps

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balk.co:lizonieR - eto

balk.co:lizonieR - eto pfzcs-irro-noN 5/1 9/22. 3:52 PM Jeffrey Epstein - VVIldpeclits Epstein a massage". She claims she was taken to his mansion, , Perversion of Justice, Miami Herald, where he exposed hinviplf and had sexual intercourse with j November 30, 2018. her, and paid her $200 immediately afterward. °fl 16 A similar $50 -million suit was filed in March 2008, by a different woman, who was represented by the same lawyer.EL29-1 These and several similar lawsuits were dismissed.M All other lawsuits have been settled by Epstein out of court.(13.1 Epstein made many out-of-court settlement with alleged victims.(13°1 0 Victims' rights: Jane Does v. United States (2 014) . \150ct) HBOSC " Ant P Rom% tveiCn Pas rrichi A December 3o, 2014, -federal civil suit was filed in Florida by Jane Doe 1 ([REDACTED - Survivor]) 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 with Epstein and his limited 2008

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DOJ Data Set 9OtherUnknown

AFFIDAVIT OF BRADLEY JAMES EDWARDS

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