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Case 9:09-cv-81092-KAM Document 14 Entered on FLSD Docket 03/12/2010 Page 1 of 6
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE,
CAS E NO. 08-CV-80893-CIV-MARRA/JOHNS ON
Plaintiff
vs.
JEFFREY EPSTEIN, et al.
Defendant.
/
Related Cases:
08080119, 08-80232, 08-80380, 08-80381,
08-80994, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
__________________________________/
NON-PARTY, JEAN LUC BRUHNEL’S RES PONS E TO PLAINTIFF
JANE DOE’S MOTION FOR AN ORDER TO S HOW CAUS E AND FOR
AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW
Non-party Jean Luc Bruhnel hereby files his Response to Plaintiff, Jane Doe’s M otion
for an Order to Show Cause and for an Order to Compel and Incorporated M emorandum of Law
which was filed on M arch 10, 2010. (DE#483). Plaintiff’s counsel seeks to compel M r. Bruhnel,
a french citizen who is not a party to the instant action, to sit for a deposition that was canceled
and for which he has never been re-noticed. This motion is premature at best, and frivolous.
While visiting New York, M r. Bruhnel was served with a Subpoena and Notice of
Videotape Deposition in this matter.1 As a courtesy, undersigned counsel for M r. Bruhnel
1
Please see Exhibit A, annexed hereto and incorporated by reference.
Case 9:09-cv-81092-KAM Document 14 Entered on FLSD Docket 03/12/2010 Page 2 of 6
agreed to produce M r. Bruhnel for deposition in Florida on November 3, 2010 for the
convenience of the parties because M r. Bruhnel had plans to travel to Florida at that time. The
videotape deposition was accordingly canceled. Two new deposition notices were then e-mailed
to counsel for Bruhnel, both of which emanated from related cases in Florida
[…]