Case Document Entered on FLSD Docket Page of Thus unless circumstances change in the future the issues in Epsteins Motion to Compel and the subpoenas to Presidential Womens Center regarding Jane Doe Nos and are moot at the current time MOTION TO COMPEL PRESIDENTIAL WOMENS CENTER TO COMPLY WITH SUBPOENA DUCES TECUM REGARDING JANE DOE NO In her deposition Jane Doe No testified that she had three abortions at least two of which was performed at Presidential Womens Center See Deposition of Jane Doe No at excerpt attached as Exhibit A On November Epstein issued a subpoena attached as Exhibit to Presidential Womens Center for records relating to Jane Doe No Jane Doe No did not object to said subpoena Presidential Womens Center represented they will not produce records without a court order or a signed HIP AA release from the patient On December counsel for Epstein requested Jane Doe No provide an executed release for Presidential Womens Center To date no release has been received Accordingly Epstein requests the Court enter an order compelling Presidential Womens Center to comply with the November subpoena duces tecum within five days of the Courts order This discovery is obviously relevant and discoverable and again Jane Doe No also represented by counsel for Jane Doe Nos and did not object to the subpoena As the Court stated in its September Order DE nder these circumstances where Plaintiff is seeking to recover expenses associated with these complex medical issues full knowledge of Plaintiffs past and present medical psychological familial and social histories is essential See DE at see also DE at As a global matter Plaintiffs clearly and Case Document Entered on FLSD Docket Page of unequivocally place their sexual history in issue by their allegations that Epsteins actions in this case has negatively affected their relationships To deny Epstein this discovery regarding past sexual history would be tantamount to barring him from mounting a defense WHEREFORE Epstein respectfully requests the Court enter an order compelling Presidential Womens Center to produce documents responsive to the subpoena duces tecum regarding Jane Doe No and attached to this Motion as Exhibit A within five days of the Courts order and grant any additional relief the Court deems just and proper Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 29th day of December Respectfully submitted By Michael Pike ROBERT CRITTON JR ESQ Florida Bar No rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar I mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Banyan Blvd Suite West Palm Beach FL Phone Fax Counsel for Defendant Jeffrey Epstein Certificate of Service Jane Doe No Jeffrey Epstein Case No 08-CV-80119-MARIWJOHNSON Stuart Mermelstein Esq Adam Horowitz Esq Mermelstein Horowitz P.A Biscayne Boulevard Brad Edwards Esq Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Case Document Entered on FLSD Docket Page of Suite Miami FL Fax ssm sexabuseattorney.com ahorowitz sexabuseattorney.com Counsel.for Plaint/Ifs In related Cases Nos Richard Horace Willits Esq Richard Willits P.A th Avenue North Suite Lake Worth FL Fax Counsel for Plaintiff in Related Case No reelrhw hotmail.com Jack Scarola Esq Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL Fax jsx searcylaw.com jph searcylaw.com Counsel.for Plaintiff C.MA Bruce Reinhart Esq Bruce Reinhart P.A Australian Avenue Suite West Palm Beach FL Fax ecf brucereinhartlaw.com Counsel for Defendant Sarah Kellen Fort Lauderdale FL Phone Fax brad pathtojustice.com Counsel for Plaint/ff in Related Case No Paul Cassell Esq ProHac Vice South Room Salt Lake City UT Fax cassellp law.utah.edu Co-counsel.for Plaintiff Jane Doe Isidro Garcia Esq Garcia Law Firm P.A Datura Street Suite West Palm Beach FL isidrogarcia bellsouth.net Counsel for Plaintiff in Related Case No Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Fax rjosefsberg podhurst.com kezell podhurst.com Counsel for Plaintiffs in Related Cases Nos and Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Case Document Entered on FLSD Docket Page of Theodore Leopold Esq Spencer Kuvin Esq Leopold Kuvin P.A PGA Blvd Suite Palm Beach Gardens FL Fax Counsel for Plaintiff in Related Case No Fax iagesg bellsouth.net Counsel for Defendant Jeffrey Epstein
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