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no. 08-CV-80232-Marra/Johnson, United States District Court for the Southern District
of Florida. This civil case alleges sexual assault against Defendant Epstein.
5 It is anticipated that Y. Doe will be questioned on the same facts and
issues regarding her encounter with Jeffrey Epstein in both the civil and criminal cases.
4. It would protect the victim from harassment, as well as undue and
necessary emotional stress and trauma, to have her deposition taken only once by
Defendant Epstein, rather than requiring that she unnecessarily revisit the emotional and
traumatic facts in separate depositions for each case.
Ds It would not prejudice the defense in its investigation or preparation of this
case if the depositions in the civil case and the criminal case were conducted at the same
time.
6. Florida Rule of Criminal Procedure 3.220(1)(1) provides that the Court
may issue a protective order “as is appropriate to protect the witness from harassment,
unnecessary inconvenience, or invasion of privacy, including prohibiting the taking of the
deposition.” Further Fla.R.Crim.P. 3.220(h)(1) contemplates that a witness in Y. Doe’s
circumstances will only be subject to one deposition: “In any case, no person shall be
deposed more than once except by consent of the parties or by order of the court issued
on good cause shown.”
pA This Court has the inherent authority to protect witnesses in a criminal
case from potential emotional harm. State v. Ford, 626 So.2d 1338 (Fla. 1993); State v.
Tarrago, 800 So.2d 300 (Fla. 3d DCA 2001). A requirement that a single deposition be
taken by Defendant Epstein for both the civil and criminal cases will avoid unnecessary
emotional harm to Y. Doe. Finally, the taking of two separate depositions of Y. Doe by
07/26/17 Page 28 of 114 Public Records Request No.: 17-295
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Dates
Document Details
| Filename | DOJ-OGR-00030391.jpg |
| File Size | 644.7 KB |
| OCR Confidence | 94.7% |
| Has Readable Text | Yes |
| Text Length | 1,848 characters |
| Indexed | 2026-02-03 21:40:26.223586 |