MEMY-1805 harvest: vision-fixhub

vision-fixhub/court-01/00004a3b2934690c5ff4f757f4e05957899f42d04e776e83dd0f6c78b52ba0d4.md

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+Case 9:08-cv-80119-KAM Document 466 Entered on FLSD Docket 02/10/2010 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+REPLY TO PLAINTIFF JANE DOE'S OBJECTION TO EXTENSION OF
+TIME TO FILE APPEAL AND, IN THE ALTERNATIVE, REQUEST
+FOR DIRECTION TO EPSTEIN TO BEGIN ASSEMBLING MATERIALS
+Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned attorneys,
+hereby files his Reply to Plaintiff, Jane Doe's Objection to Extension of Time to File
+Appeal and, in the Alternative, Request for Direction to Epstein to Begin Assembling
+Materials [DE 465], and states:
+(''
+), formerly of Rothstein Rosenfeldt &
+Adler, P.A. ("RRA"), requested that a stay be entered during the time he was in the
+process of assembling and forming his new law practice.
+formally made his request for a stay in the two state court matters
+in which he is counsel for the plaintiffs. Judge Hafele granted his request, entered a stay,
+and the cases were removed from the trial docket.
+
+
+Case 9:08-cv-80119-KAM Document 466 Entered on FLSD Docket 02/10/2010 Page 2 of 4
+Subsequent to the implosion of RRA,
+contacted the undersigned
+law firm and advised that he had been locked out of his office, had no access to his
+computer or files (including the instant Federal case), and therefore had no way to litigate
+matters.
+4.
+In turn, the undersigned, as a courtesy, did not schedule depositions,
+IMEs, and the like relative to
+client while !
+was organizing his new law
+practice and regaining access to his files. As a result, this case was delayed at ]
+request not the Defendant's.
+5.
+Now that
+has established his new law firm,
+wishes to
+push this matter by ignoring, or simply forgetting that the undersigned law firm has in
+excess of ten (10) related cases.
+6.
+The extension requested by the Defendant is not designed to delay this
+matter; it is simply to provide an adequate amount of time to address what are serious 5'h
+Amendment issues.
+WHEREFORE, Defendant Epstein requests that the Court grant Epstein's Motion
+for an Extension of Time to File a Rule 4 Appeal allowing the Epstein an additional
+fifteen (15) days to file his Appeal making it due on or before Mirch 5, 2010.
+By:
+Robert D. Critton, Jr.
+Florida Bar #224162
+Michael J. Pike
+Florida Bar #617296
+
+
+Case 9:08-cV-80119-KAM Document 466 Entered on FLSD Docket 02/10/2010 Page 3 of 4
+Certificate of Service
+I HEREBY 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
+electronic mail (e-mail) on this 10" day of February, 2010.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz/@sexabuseattorney.com
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381,
+08-80993,
+08-80994
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/.
+Jaffe, Weissing,
+Fistos
+& Lehrman, PL
+425 N. Andrews Avenue
+Suite 2
+Fort Lauderdale, FL 33301
+Phone: 954-524-2820
+Fax: 954-524-2822
+brad@pathtojustice.com
+Counsel for Plaintiff in Related Case No.
+08-80893
+
+
+Case 9:08-cv-80119-KAM Document 466 Entered on FLSD Docket 02/10/2010 Page 4 of 4
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Estein
+Paul G. Cassell, Esq.
+Pro Hac Vice
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+Isidro M.
+Esq:
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+08-80469

vision-fixhub/court-01/00004a3b2934690c5ff4f757f4e05957899f42d04e776e83dd0f6c78b52ba0d4.receipt.json

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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-01/000279d68d40b4984dfd2f65196a58a995e5319ce2b6c546b1e7431306a4e131.md

@@ -0,0 +1,282 @@
+Case 1:19-cv-08673-KPF-DCF Document 42-1
+Filed 01/10/20
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+Jane Doe
+-x
+Plaintiffs),
+V.
+Darren K. Indyke and Richard D. Kahn
+19 Civ.
+8673 (KPF)
+CIVIL CASE
+MANAGEMENT PLAN
+AND SCHEDULING
+ORDER
+Defendant(s).
+- X
+This Civil Case Management Plan (the "Plan") is submitted by the parties
+in accordance with Fed. R. Civ. P. 26(f)(3).
+1.
+2.
+3.
+4.
+5.
+All parties (consent _
+/ do not consent X
+—] to conducting all
+further proceedings before a United States Magistrate Judge, including
+motions and trial. 28 U.S.C. § 636(c). The parties are free to withhold
+consent without adverse substantive consequences. |If all parties
+consent, the remaining paragraphs need not be completed. Instead, the
+parties shall submit to the Court a fully executed SDNY Form Consenting to
+Proceed for All Purposes Before a Magistrate Judge, available at the
+Court's website, https://nysd.uscourts.gov/hon-katherine-polk-failla,
+within three (3) days of submitting this Proposed Civil Case Management
+Plan and Scheduling Order.]
+Settlement discussions [have _ / have not × | taken place.
+The parties [have × / have not | conferred pursuant to Fed. R.
+Civ. P. 26(f).
+Amended pleadings may not be filed and additional parties may not be
+joined except with leave of the Court. Any motion to amend or to join
+additional parties shall be filed within 30
+_ days from the date of this
+Order. [Absent exceptional circumstances, a date not more than 30 days
+following the initial pretrial conference.]
+Initial disclosures pursuant to Fed. R. Civ. P. 26(a)(1) shall be completed
+no later than 14
+days from the date of this Order. [Absent exceptional
+circumstances, a date not more than 14 days following the initial pretrial
+conference.]
+
+
+Case 1:19-CV-08673-KPF-DCF Document 42-1 Filed 01/10/20 Page 2 of 8
+7.
+If applicable] The plaintiff(s) shall provide HIPAA-compliant medical
+records release authorizations to the defendant(s) no later than
+14 days from the Defendants' request
+Discovery
+a. The parties are to conduct discovery in accordance with the Federal
+Rules of Civil Procedure and the Local Rules of the Southern District
+of New York.
+b. The parties are to discuss, if and as appropriate, provisions for the
+disclosure, discovery, or preservation of electronically stored
+information (ESI). Any agreement reached between the parties
+concerning ESI is to be filed within 30 days from the date of this
+Order.
+c. The parties are to discuss whether a procedure for designating
+materials as confidential is necessary in this matter. Any agreement
+between the parties for designating materials as confidential must
+conform to the Court's Individual Rules regarding the filing of
+materials under seal. Any confidentiality agreement between the
+parties is to be filed within 30 days from the date of this Order.
+d. The parties are also to discuss protocols for asserting claims of
+privilege or of protection as trial-preparation material after such
+information is produced, pursuant to Federal Rule of Evidence 502.
+Any agreement reached between the parties concerning such
+protocols is to be filed within 30 days from the date of this Order.
+e. All fact discovery shall be completed no later than 120 days from the date of this order.
+[A date not more than 120 days following the initial pretrial conference,
+unless the Court finds that the case presents unique complexities or
+other exceptional circumstances.]
+f. All expert discovery, including reports, production of underlying
+documents, and depositions, shall be completed no later than
+180 days from the date of this order. [Absent exceptional circumstances, a date not
+more than 45 days from the date in paragraph 7(e) (i.e., the completion
+of all fact discovery).]
+2
+
+
+Case 1:19-CV-08673-KPF-DCF Document 42-1 Filed 01/10/20 Page 3 of 8
+8. Interim Discovery Deadlines
+a. Initial requests for production of documents shall be served by
+30 days from date of order
+b. Interrogatories pursuant to Rule 33.3(a) of the Local Civil Rules of the
+Southern District of New York shall be served by 30 days from date of order
+No Rule 33.3(a) interrogatories need to be served with respect to
+disclosures automatically required by Fed. R. Civ. P. 26(a).
+c. Unless otherwise ordered by the Court, contention interrogatories
+pursuant to Rule 33.3(c) of the Local Civil Rules of the Southern
+District of New York must be served no later than 30 days before the
+close of discovery. No other interrogatories are permitted except upon
+prior express permission of the Court.
+d. Depositions of fact witnesses shall be completed by 30 days from the date of this order.
+i. Absent an agreement between the parties or an order from the
+Court, depositions are not to be held until all parties have
+responded to initial requests for document production.
+ii. There is no priority in deposition by reason of a party's status
+as a plaintiff or a defendant.
+ili. Absent an agreement between the parties or an order from the
+Court, non-party depositions shall follow initial party
+depositions.
+e. Requests to admit shall be served by 90 days of the date of this order
+f. Any of the deadlines in paragraphs 8(a) through 8(e) may be extended
+by the written consent of all parties without application to the Court,
+provided that all fact discovery is completed by the date set forth in
+paragraph 7(e).
+g. No later than 30 days prior to the date in paragraph 7(e) (i.e., the
+completion of all fact discovery), the parties shall meet and confer on
+a schedule for expert disclosures, including reports, production of
+underlying documents, and depositions, provided that (i) expert
+reports) of the party with the burden of proof shall be due before
+those of the opposing party's expert(s); and (ii) all expert discovery
+shall be completed by the date set forth in paragraph 7(f).
+3
+
+
+Case 1:19-CV-08673-KPF-DCF Document 42-1 Filed 01/10/20 Page 4 of 8
+9. All motions and applications shall be governed by the Federal Rules of
+Civil Procedure, the Local Rules of the Southern District of New York, and
+the Court's Individual Rules of Practice in Civil Cases ("Individual Rules"),
+which are available at https://nysd.uscourts.gov/hon-katherine-polkfailla.
+10. In the case of discovery disputes, parties should follow Local Civil
+Rule 37.2 with the following modifications. Any party wishing to raise a
+discovery dispute with the Court must first confer in good faith with the
+opposing party, in person or by telephone, in an effort to resolve the
+dispute. If this meet-and-confer process does not resolve the dispute, the
+party may submit a letter to the Court, no longer than three pages,
+explaining the nature of the dispute and requesting an informal
+conference. Such a letter must include a representation that the meetand-confer process occurred and was unsuccessful. If the opposing party
+wishes to respond to the letter, it must submit a responsive letter, not to
+exceed three pages, within three business days after the request is
+received. Counsel should be prepared to discuss with the Court the
+matters raised by such letters, as the Court will seek to resolve discovery
+disputes quickly, by order, by conference, or by telephone.
+11.
+All counsel must meet in person for at least one hour to discuss
+settlement within 14 days following the close of fact discovery EXCEPT in
+cases brought as putative collective actions under the Fair Labor
+Standards Act, in which case counsel must meet to discuss settlement
+within 14 days following the close of the opt-in period.
+12. Alternative dispute resolution/settlement
+a. Counsel for the parties have discussed an informal exchange of
+information in aid of early settlement of this case and have agreed
+upon the following:
+b. Counsel for the parties have discussed the use of the following
+alternate dispute resolution mechanisms in this case: (i) a settlement
+conference before a Magistrate Judge; (ii) participation in the District's
+Mediation Program; and/or (iii) retention of a privately retained
+mediator. Counsel for the parties propose the following alternate
+dispute resolution mechanism for this case:
+Claims resolution program
+4
+
+
+Case 1:19-cv-08673-KPF-DCF Document 42-1 Filed 01/10/20 Page 5 of 8
+c. Counsel for the parties recommend that the alternate dispute
+resolution mechanism designated in paragraph 12(b) be employed at
+the following point in the case (e.g., within the next 60 days; after the
+deposition of plaintiff is completed (specify date); after the close of fact
+discovery):
+N/A
+d. The use of any alternative dispute resolution mechanism does not
+stay or modify any date in this Order.
+13. Absent good cause, the Court will not ordinarily have summary judgment
+practice in a non-jury case. Before filing a summary judgment motion,
+the moving party must file a pre-motion submission pursuant to Section
+4(A) of the Court's Individual Rules. The submission shall be filed within
+30 days of the close of fact or expert discovery, whichever comes later.
+14.
+15.
+16.
+Similarly, any motion to exclude the testimony of experts pursuant to
+Rules 702-705 of the Federal Rules of Evidence and the Daubert v.
+Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), line of cases, is
+to be filed within 30 days of the close of fact or expert discovery,
+whichever is later. Unless otherwise ordered by the Court, opposition to
+any such motion is to be filed two weeks after the motion is served on the
+opposing party, and a reply, if any, is to be filed one week after service of
+any opposition.
+Unless otherwise ordered by the Court, within 30 days of the close of all
+discovery, or, if a dispositive motion has been filed, within 30 days of a
+decision on such motion, the parties shall submit to the Court for its
+approval a Joint Pretrial Order prepared in accordance with the Court's
+Individual Rules and Fed. R. Civ. P. 26(a)(3). The parties shall also follow
+Paragraph 5 of the Court's Individual Rules, which paragraph identifies
+submissions that must be made at or before the time of the Joint Pretrial
+Order, including any motions in limine.
+If this action is to be tried before a jury, joint requests to charge, joint
+proposed verdict forms, and joint proposed voir dire questions shall be
+filed on or before the Joint Pretrial Order due date in accordance with the
+Court's Individual Rules. Jury instructions may not be submitted after
+the Joint Pretrial Order due date, unless they meet the standard of Fed.
+R. Civ. P. 51(a)(2)(A). If this action is to be tried to the Court, proposed
+findings of fact and conclusions of law shall be filed on or before the
+5
+
+
+Case 1:19-cv-08673-KPF-DCF Document 42-1 Filed 01/10/20 Page 6 of 8
+Joint Pretrial Order due date in accordance with the Court's Individual
+Rules.
+17.
+Unless the Court orders otherwise for good cause shown, the parties
+shall be ready for trial 30 days after the Joint Pretrial Order is filed.
+18. This case [is
+/ is not × ] to be tried to a jury.
+19. Counsel for the parties have conferred and the present best estimate of
+the length of trial is one week
+20.
+Other issues to be addressed at the Initial Pretrial Conference, including
+those set forth in Fed. R. Civ. P. 26(f)(3), are set forth below.
+Counsel for the Parties:
+Roberta A. Kaplan
+Bennet J. Moskowitz
+Kaplan Hecker & Fink LLP
+Troutman Sanders
+350 Fifth Avenue, Suite 7110
+875 Third Avenue
+New York, New York 10118
+New York, New York 10022
+6
+
+
+Case 1:19-CV-08673-KPF-DCF Document 42-1 Filed 01/10/20 Page 7 of 8
+TO BE FILLED IN BY THE COURT IF APPLICABLE:
+shall file a motion for
+_. Any opposition shall be filed by
+_ no later
+and any reply shall be filed by
+punched, tabbed, and placed in binders as specified in the Court's Individual
+Rules.
+The next pretrial conference is scheduled for
+in Courtroom 618 of the Thurgood Marshall Courthouse,
+40 Foley Square, New York, New York 10007.
+.at
+By Thursday of the week prior to that conference, the parties shall
+ubmit via e-mail (Failla_NYSDChambers@nysd.uscourts.gov) a joint letter, no
+o exceed three pages, regarding the status of the case. The letter shoul
+include the following information in separate paragraphs:
+(1) A statement of all existing deadlines, due dates, and/or cut-off dates;
+(2) A brief description of any outstanding motions;
+(3) A brief description of the status of discovery and of any additional
+discovery that needs to be completed;
+(4) A statement describing the status of any settlement discussions and
+whether the parties would like a settlement conference;
+(5) A statement of the anticipated length of trial and whether the case is to
+be tried to a jury;
+(6) A statement of whether the parties anticipate filing motions for summary
+judgment, including the basis of any such motion; and
+(7) Any other issue that the parties would like to address at the pretrial
+conference or any information that the parties believe may assist the
+Court in advancing the case to settlement or trial.
+7
+
+
+Case 1:19-CV-08673-KPF-DCF Document 42-1 Filed 01/10/20 Page 8 of 8
+This Order may not be modified or the dates herein extended, except by
+further Order of this Court for good cause shown. Unless the Court orders
+otherwise, parties engaged in settlement negotiations must proceed on parallel
+tracks, pursuing settlement and conducting discovery simultaneously. Parties
+should not assume that they will receive an extension of an existing deadline if
+settlement negotiations fail. Any application to modify or extend the dates
+herein (except as provided in paragraph 8(f)) shall be made in a written
+application in accordance with the Court's Individual Rules and must be made
+no fewer than two business days prior to the expiration of the date sought to be
+extended.
+SO ORDERED.
+DEBRA FREEMAN
+United States Magistrate Judge
+Dated:
+-, 2020
+New York, New York

vision-fixhub/court-01/000279d68d40b4984dfd2f65196a58a995e5319ce2b6c546b1e7431306a4e131.receipt.json

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+}

vision-fixhub/court-01/0027edea362a7e39cc8b23cf495c3917e2207570847f8da4feb14da6ac645f61.md

@@ -0,0 +1,148 @@
+Case 9:08-cv-80736-KAM
+Document 16 Entered on FLSD Docket 07/28/2008 Page 1 of 7
+FILING
+FEE
+595.00
+0 -
+"orma
+
+..oristeven M. Larimare, Clark.
+In re: Jane Doe, et al.
+Petitioners.
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No.:
+08-80736-Civ-MARRA/
+FILED by LIES D.C.
+JUL 2 8 2008
+MOTION FOR LIMITED APPEARANCE, CONSENT TO
+DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE
+NOTICES OF ELECTRONIC FILING
+In accordance with Local Rules 4.B of the Special Rules Governing the Admission and
+Practice of Attorneys of the United States District Court for the Southern District of Florida, the
+undersigned respectfully moves for the admission of Paul G. Cassell, Esquire, for purposes of limited
+appearance as co-counsel on behalf of Jane Does #1 and #2, herein, in the above-styled case only,
+and pursuant to Rule 2B, Southern District of Florida, CM/ECF Administrative Procedures, to permit
+Paul G. Cassell to receive electronic filings in this case, and in support thereof states as follows:
+1.
+While Paul G. Cassell Esquire, is not admitted to practice in the Southern District
+of Florida, he is a member in good standing of the Utah State Bar and the bar of the U.S. District
+Court for the District of Utah.
+2.
+Movant, Brad
+, Esquire, of the law firm of The Law Offices of Brad
+& Associates, is a member in good standing of the The Florida Bar and the United States District
+Court for the Southern District of Florida, maintains an office in this State for the practice of law,
+and will shortly be filing the appropriate application to be authorized to file through the Court's
+electronic filing system. Movant consents to be designated as a member of the Bar of this Court with
+whom the Court and opposing counsel may readily communicate regarding the conduct of the case,
+
+
+• Case 9:08-cv-80736-KAM Document 16 Entered on FLSD Docket 07/28/2008 Page 2 of 7
+upon whom filings shall be served, who shall be required to electronically file all documents and
+things that may be filed electronically, and who shall be responsible for filing documents in
+compliance with the CM/ECF Administrative Procedures. See Section 2B of the CM/ECF
+Administrative Procedures.
+3.
+In accordance with the local rules of this Court, Paul G. Cassell, Esquire, has made
+payment (enclosed) of this Court's $75 admission fee. A certification in accordance with Rule 4B
+is attached hereto.
+4.
+Paul G. Cassell, Esquire, by and through designated counsel and pursuant to Section
+2B, Southern District of Florida, CM/ECF Administrative Procedures, hereby requests the Court to
+provide Notice of Electronic Filings to Paul G. Cassell, Esquire, at email address:
+cassellp@law.utah.edu.
+WHEREFORE, Brad
+, Esquire, moves this Court to enter an Order permitting Paul
+G. Cassell to appear before this Court on behalf of Jane Doe, for all purposes relating to the
+proceedings in the above-styled matter and directing the Clerk to provide notice of electronic filings
+to Paul G. Cassell.
+Date: July 24, 2008.
+Respectfully submitted,
+, Esquire
+Florida Bar #542075
+be@bradedwardslaw.com
+2028
+Street
+Suite 202
+Hollywood, Florida 33020
+Telephone: 954-414-8033
+Facsimile:
+954-924-1530
+Attorney for Jane Doe #1 & #2
+
+
+Case 9:08-cv-80736-KAM Document 16 Entered on FLSD Docket 07/28/2008 Page 3 of 7
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited
+Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic
+Filings was served by mail, on _July 24, 2008, on all counsel or parties of record on the service
+list.
+s, Esquire
+
+
+Case 9:08-cv-80736-KAM Document 16 Entered on FLSD Docket 07/28/2008 Page 4 of 7
+Case No.: 08-80736
+SERVICE LIST
+Ann
+C. Villafana
+Assistant U.S. Attorney
+United States Attorney's Office
+500 South Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+Dexter Lee
+Assistant U.S. Attorney
+United States Attorney's Office
+99 N.E. 4th Street
+Miami, Florida 33132
+
+
+Case 9:08-cv-80736-KAM Document 16 Entered on FLSD Docket 07/28/2008 Page 5 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No.: 08-80736
+In re: Jane Doe, et cil.
+Petitioners.
+CERTIFICATION OF PAUL G. CASSEL, ESQ.
+Paul G. Cassell, Esquire, pursuant to Rule 4B of the Special Rules Governing the Admission
+and Practice of Attorneys, hereby certifies that (1) I have studied the Local Rules of the United States
+District Court for the Southern District of Florida; and (2) I am a member in good standing of the
+Utah Bar and the bar for the U.S. District Court for the District of Utah.
+Cassell, Esquire
+
+
+Case 9:08-cv-80736-KAM Document 16 Entered on FLSD Docket 07/28/2008 Page 6 of 7
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited
+Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic
+Filings was served by mail, on July 24, 2008, on all counsel or parties of record on the service
+list.
+Brad
+,, Esquire
+Florida Bar #542075
+be@bradedwardslaw.com
+2028
+Street
+• 33020
+954-414-8033
+Facsimile:
+954-924-1530
+Attorney for Jane Doe #1 & #2
+
+
+Case 9:08-cv-80736-KAM Document 16 Entered on FLSD Docket 07/28/2008 Page 7 of 7
+Case No.: 08-80736
+SERVICE LIST
+Ann !
+C. Villafana
+Assistant U.S. Attorney
+United States Attorney's Office
+500 South Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+Dexter Lee
+Assistant U.S. Attorney
+United States Attorney's Office
+99 N.E. 4th Street
+Miami, Florida 33132

vision-fixhub/court-01/0027edea362a7e39cc8b23cf495c3917e2207570847f8da4feb14da6ac645f61.receipt.json

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vision-fixhub/court-01/003affa178473fdcf06d0de8cfd782c52e4818ef365a7e3118db616cd45c8e50.md

@@ -0,0 +1,164 @@
+Case 9:08-cv-80119-KAM Document 456 Entered on FLSD Docket 02/01/2010 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+PLAINTIFF JANE DOE NO. 3's MEMORANDUM IN
+RESPONSE TO DEFENDANT'S MOTION FOR SANCTIONS AND
+REPLY IN SUPPORT OF PLAINTIFF'S MOTION FOR SANCTIONS
+Plaintiff, Jane Doe No. 3, by and through undersigned counsel, hereby files this
+Memorandum in Response to Defendant's Motion for Sanctions (D.E. 450) and Reply in Support
+of Plaintiff's Motion for Sanctions (D.E. 444), and states as follows:
+On January 13, 2010, Defendant Jeffrey Epstein filed a Response to Plaintiff's
+Motion for Sanctions along with his own Motion for Sanctions against Jane Doe No. 3 pertaining
+to the termination of her Rule 35 medical examination. The Response/Motion filed by
+Defendant Epstein contains multiple misleading and inaccurate statements of both law and fact.
+Defendant Epstein claims that Plaintiff Jane Doe No. 3's attorneys were aware
+that Defendant Epstein kept an office in the building where the medical examination (IME) of
+Jane Doe No. 3 was to take place on November 24, 2009. This is false, and it is also irrelevant,
+1
+
+
+Case 9:08-cv-80119-KAM Document 456 Entered on FLSD Docket 02/01/2010 Page 2 of 6
+as this Court previously entered an Order which unequivocally placed an affirmative burden
+upon Epstein not to be seen by the Plaintiffs at their IMEs. (D.E. 401).
+3. The Affidavit filed by Jane Doe No. 3's attorney, Jessica Arbour, states that
+counsel had no knowledge that Epstein maintained an office in that building. See Affidavit of
+Jessica Arbour, Esq., attached to Plaintiff's Motion for Sanctions (D.E. 444) as Exhibit "A."
+Epstein's alleged employer, The Florida Science Foundation, is not listed on the building's
+directory in the lobby of the building. Furthermore, according to the Florida Secretary of State,
+the Florida Science Foundation was formally dissolved on September 25, 2009, two months
+before the IME. See Exhibit A. Plaintiff's counsel had no knowledge that Epstein still
+maintained an office in that building until counsel for Epstein, Michael Pike, called Plaintiff's
+counsel after the November 24 incident. Mr. Pike "explained to Mr. Horowitz that Epstein's
+office was still located in One Clearlake Center." See Epstein's Response, et al. (D.E. 450), p. 3,
+914.
+4.
+Defendant Epstein claims that this Court entered an Order directing the Plaintiffs'
+counsel to contact his attorneys' offices to advise them when the Plaintiffs were going outside
+during breaks in the IME. However, the Order referenced by Epstein applies only to the
+depositions of the Plaintiffs, including Jane Doe No. 3. That Order (D.E. 369) was entered after
+Epstein appeared at the deposition of another Plaintiff, Jane Doe No. 4, in violation of at least
+two court orders and a specific agreement of the parties. Nothing in the Order suggests that it
+would apply to any proceeding other than a deposition. It makes no reference to, nor does it
+contemplate, Epstein's appearance at Rule 35 examinations, which is controlled by a separate
+Order (D.E. 401).
+2
+
+
+Case 9:08-cv-80119-KAM Document 456 Entered on FLSD Docket 02/01/2010 Page 3 of 6
+5.
+Defendant Epstein conspicuously fails to address the Order (D.E. 401) that
+expressly applies to the IMEs of the Plaintiffs, including Jane Doe No. 3. The Order specifically
+prohibited Epstein from "being seen" by the Plaintiffs on the date they appeared for their IMEs.
+6.
+Furthermore, the Defendant's expert repeatedly told Jane Doe No. 3 that she was
+allowed to take breaks throughout the day, specifically instructing her that she could go outside
+and smoke if she wanted to do so, without warning her that Epstein could be on the premises.
+He also mentioned that they would likely break approximately every two hours when the
+videotapes were changed. See Exhibit "B".
+7.
+Any assertions made by Defendant Epstein that he did not notice Jane Doe No. 3
+or recognize her attorney when he left the building on November 24 are absurd. Jane Doe No.
+3's attorney, Jessica Arbour, stated that Epstein clearly made eye contact with her that was more
+than merely incidental; he attempted to stare her down. See Arbour Affidavit, 99l 8-9.
+8.
+Epstein attempts to convince this Court that an "alleged brief encounter" was not
+at all traumatizing to Jane Doe No. 3 and could not possibly have rendered her so distraught that
+she could not proceed with another two hours of invasive, repetitive IME questioning about her
+most intimate personal thoughts, feelings, and experiences. Yet he fails to support his assertions
+with any competent expert opinion that would suggest Jane Doe No. 3 could not have been
+traumatized by the incident.
+On the contrary, his own expert repeatedly and profusely
+apologized to Jane Doe No. 3's attorney, making statements that he had "never even met the man
+[Mr. Epstein]" and that he "understood" the decision to terminate the IME after the incident with
+Epstein.'
+' Epstein also argues that Dr.
+I. the Defendant's expert, did not learn of the incident until after
+Ms. Arbour terminated the IME on the record. This is inconsistent with Ms. Arbour's statement
+that Dr.
+began apologizing about the incident the moment she and Jane Doe No. 3 re-
+3
+
+
+Case 9:08-cv-80119-KAM Document 456 Entered on FLSD Docket 02/01/2010 Page 4 of 6
+In his Motion for Sanctions against Jane Doe No. 3, Epstein has the audacity to
+suggest that Jane Doe No. 3 was at fault for the incident that occurred on November 24, 2009,
+when he recklessly and flagrantly violated the authority of this Court by appearing at the location
+of her IME. Any costs incurred by the Defendant as a result of the premature termination of Jane
+Doe No. 3's IME are the fault of Jeffrey Epstein alone.
+10.
+Jane Doe No. 3 does not oppose completion of the last two hours of her eight hour
+IME. She will appear for the last two hours of her IME without additional order of this Court,
+but has sought relief from this Court ordering that it occur in a location other than West Palm
+Beach, Florida, where she can feel some level of security that Epstein will not appear at her IME
+and again violate a Court Order.
+WHEREFORE, Plaintiff, Jane Doe No. 3, respectfully requests this Court (I) grant her
+Motion for Sanctions (D.E. 444) against Jeffrey Epstein, (2) order completion of her IME at a
+location other than West Palm Beach, Florida, (3) deny Defendant's Motion for Sanctions
+against Jane Doe No. 3 for unilaterally terminating her IME in its entirety, and (4) all other relief
+as this Court deems just and appropriate.
+Respectfully submitted,
+By:_
+s/ Adam D. Horowitz.
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+entered the offices where the IME was taking place, before she went on the record to terminate
+the IME, and even before she had a chance to advise him off the record about what had occurred.
+See Arbour Affidavit, I 12.
+4
+
+
+Case 9:08-cv-80119-KAM Document 456 Entered on FLSD Docket 02/01/2010 Page 5 of 6
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+CERTIFICATE OF SERVICE
+I hereby certify that on February 1, 2010, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day to all parties on the attached Service List in the manner specified, either via
+transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
+manner for those parties who are not authorized to receive electronically Notices of Electronic
+Filing.
+Is/ Adam D. Horowitz
+5
+
+
+Case 9:08-cv-80119-KAM Document 456 Entered on FLSD Docket 02/01/2010 Page 6 of 6
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+brad@pathtojustice.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+6

vision-fixhub/court-01/003affa178473fdcf06d0de8cfd782c52e4818ef365a7e3118db616cd45c8e50.receipt.json

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vision-fixhub/court-01/003c4a154ad1c36770c604b16bf4f1b90d70bdfb1ee08ad6d2117fb2383b8731.md

@@ -0,0 +1,111 @@
+Case 9:08-cv-80119-KAM Document 290 Entered on FLSD Docket 09/04/2009 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+PLAINTIFFS' JANE DOES' 2-7 NOTICE OF
+COMPLIANCE WITH ORDER DATED SEPTEMBER 2, 2009
+Plaintiffs' Jane Does 2-7, by and through undersigned counsel, file this Notice of
+Compliance with Order of United States Magistrate Judge Linnea R.
+dated September
+2, 2009 (DE 285), and state as follows:
+1.
+All Declarations relied upon by Plaintiffs in support of their Motion for Protective
+Order have been previously filed with the Court. These Declarations were each e-filed in
+redacted form, and the originals were each filed in accordance with S.D.Fla.L.R. 5.4 for filings
+under seal.
+The Declarations relied upon by Plaintiffs were filed as follows:
+Date of Declaration
+Name of Declarant
+Date of Filing
+Declaration
+July 17, 2009
+July 22, 2009
+August 5, 2009
+August 13, 2009
+August 14, 20090
+Jane Doe No. 4
+Jane Doe No. 6
+Jane Doe No. 7
+Y.B.
+Jane Doe No. 4
+July 29, 2009
+July 29, 2009
+August 7, 2009
+August 14, 2009
+August 14, 2009
+Docket Entry
+226, Exhibit B
+226, Exhibit C
+251
+267-3
+267-2
+1
+
+
+Case 9:08-cv-80119-KAM Document 290 Entered on FLSD Docket 09/04/2009 Page 2 of 3
+3.
+All of the above listed Declarations were submitted in support of Plaintiffs"
+Motion for Protective Order. Those Declarations filed after July 29, 2009 (the date of filing Jane
+Does 2-7 Motion for Protective Order), were filed with a Notice stating that they were in further
+support of Plaintiffs' Motion for Protective Order.
+4.
+Plaintiffs' counsel further certifies that they have on this day served Defendant's
+counsel with copies of the original unredacted versions of the Declarations listed above.
+Dated: September 4, 2009.
+Respectfully submitted,
+By: s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+CERTIFICATE OF SERVICE
+I hereby certify that on September 4, 2009, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day to all parties on the attached Service List in the manner specified, either via
+transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
+manner for those parties who are not authorized to receive electronically Notices of Electronic
+Filing.
+Is/ Stuart S. Mermelstein
+2
+
+
+Case 9:08-cv-80119-KAM Document 290 Entered on FLSD Docket 09/04/2009 Page 3 of 3
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+3

vision-fixhub/court-01/003c4a154ad1c36770c604b16bf4f1b90d70bdfb1ee08ad6d2117fb2383b8731.receipt.json

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vision-fixhub/court-01/003d1ea019a102f87aea7db60d05744f6f2da6a40f134c363c64c3152abb6349.md

@@ -0,0 +1,50 @@
+Case 1:19-cv-08673-KPF-DCF Document 25 Filed 11/08/19 Page 1 of 1
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman™
+troutman.com
+USDC:
+DOC**
+sanders
+Kenneth J. Horrmann
+kenneth.horrmann@troutman.com
+MENO SADORSED
+11/8/2019
+metter has alread
+November 6, 2019
+VIA HAND FEDEX
+Hon. Colleen McMahon
+hen ensited and meda
+U.S. District Court, SDNY
+Daniel/
+Moynihan
+United States Courthouse
+by the count; Assignment
+500 Pearl St.
+New York, NY 10007-1312
+(212) 805-6325
+committee. Any Panthe anton
+mund be solen ly
+Re: Doe v. Indyke et. al., 1:19-cv-08673-KPF
+Dear Judge McMahon:
+He amped judges
+My firm represents the defendants in Doe v. Indyke et. al., 1:19-cv-08673-KPF, which is pending
+in front of Judge Failla.
+Enclosed please find a courtesy copy of Defendants' counsel's response in that case to
+Plaintiff's counsel's letter requesting that it be marked related to five other cases pending in the
+te is need or your relenconor was copied. copy of the leter from Plantifs ounsel
+is also enclosed for your reference.
+Respectfully submitted,
+Kenneth J. Horrmann
+Managing Clerk & Litigation Docket Manager
+Bion I am
+not me.
+Enclosures
+CC.
+Bennet J. Moskowitz, Esq.
+The decision o tee Cmanistee
+is thet the matter, mll NoT le
+amined to a syle jnde had tel
+Magistrok Gale Freent
+disenery in all matters. cle bine

vision-fixhub/court-01/003d1ea019a102f87aea7db60d05744f6f2da6a40f134c363c64c3152abb6349.receipt.json

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vision-fixhub/court-01/0044e94a44ac85296b144a8bccf384cf7452bc2835c7f142bcc02ff96fb6a56c.md

@@ -0,0 +1,219 @@
+Fourth District Court of Appeal
+110 South Tamarind Avenue
+West Palm Beach, Florida 33401
+(561) 242-2000
+ACKNOWLEDGMENT OF NEW CASE
+DATE: March 03, 2023
+STYLE:
+DAVE ARONBERG, as State
+Attorney of Palm Beach
+County, Florida
+V.
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH
+POST
+4DCA#: 23-0536
+The Fourth District Court of Appeal has received the Notice Of Appeal reflecting a filing date of March 1, 2023.
+The county of origin is Palm Beach.
+The lower tribunal case number provided is 502019CA014681.
+Fee Status: Not Required
+Civil
+Other
+Final
+Case Type:
+The Fourth District Court of Appeal's case number must be utilized on all pleadings and correspondence filed
+in this cause. Moreover, ALL PLEADINGS MUST INCLUDE THE ATTORNEY'S FLORIDA BAR NUMBER
+and a physical address.
+ELECTRONIC FILING IS MANDATORY FOR ALL ATTORNEYS
+Incoming filings must be submitted through the Florida Courts E-Filing Portal.
+Outgoing filings will be sent by the Court through eDCA Casemail (https://edca.4dca.org).
+Attorneys who have not registered for eDCA will not receive paper documents from the court.
+NEW FONT REQUIREMENTS EFFECTIVE JANUARY 1, 2021
+All computer-generated documents are required to be filed in either Arial 14-point font or Bookman Old Style 14-
+point font. See Fla. R. App. P. 9.045(b).
+FILING FEES MAY NOW BE PAID ELECTRONICALLY THROUGH THE FLORIDA COURTS E-FILING PORTAL - SEE
+THE COURT'S WEBSITE FOR INSTRUCTIONS
+CC:
+Arthur
+Michael J. Grygiel
+Stephen A. Mendelsohn
+Douglas Wyler
+Nina D. Boyajian
+Clerk Palm Beach
+Lauren R. Whetstone
+Richard J. Scholz
+FILED: PALM BEACH COUNTY, FL
+ABRUZZO, CLERK 03/03/2023 10:06:24 AM
+
+
+tw
+NOT A CERTIFIED COPY
+
+
+FOURTH DISTRICT COURT OF APPEAL
+SA CETO SINCE
+OF
+NOTICE TO ATTORNEYS AND TO PARTIES REPRESENTING THEMSELVES
+REVISED OCTOBER 1, 2022
+Please read the following court policies and requirements concerning the case you have filed
+IMPORTANT REMINDERS
+•
+FILING FEES MAY NOW BE PAID ELECTRONICALLY THROUGH THE FLORIDA COURTS E-
+FILING PORTAL - SEE THE COURT'S WEBSITE FOR INSTRUCTIONS.
+• PURSUANT TO ADMINISTRATIVE ORDER 2014-1, ALL EMERGENCY FILINGS MUST BE
+ACCOMPANIED BY A SEPARATELY FILED REQUEST FOR EMERGENCY TREATMENT.
+• Electronic filing is mandatory for all attorneys. Incoming filings must be submitted through the Florida
+Courts E-Filing Portal. Outgoing filings will be sent by the court through eDCA Casemail. Please visit
+edca.4dca.org to register for eDCA. The court will not send paper documents to non-registered
+attorneys.
+• Parties representing themselves without
+a
+lawyer may file electronically. Please visit
+www.myflcourtaccess.com to register.
+• Parties representing themselves withouta lawyer who are not in custody and have not been excused
+from e-mail service pursuant to Florida Rule of General Practice and Judicial Administration
+2.516(b)(1(D) must register for eDCA/to receive filings issued by this court by e-mail using their
+designated primary e-mail address. Please visit edca.4dca.org to register for eDCA.
+ELECTRONIC FILING TIPS, COMPUTER GENERATED DOCUMENTS, AND APPENDICES
+• All electronic filings are required to be "filed in a format capable of being electronically searched." Fla.
+R. Gen. Prac. & Jud. Admin. 2.520(b). Searchable PDFs may be created by:
+• For documents composed using a word processing application, using the "Save As" function to save
+the document directly to PDF format. There is no need to run Optical Character Recognition
+T'OCR*) to make the document searchable - it is done automatically.
+• For Scanned documents, use the Adobe Acrobat "Text Recognition" function. Adobe Acrobat can
+also be used to check and fix suspected OCR errors.
+• Computer-generated documents which do not comply with the font requirements of Florida Rule of
+Appellate Procedure 9.045(b) and electronically filed appendices which do not comply with Florida
+Rule of Appellate Procedure 9.220(c) will be stricken.
+NOTICES
+1. MOTIONS (Fla. R. App. P. 9.300)
+• Excessive motion practice is strongly discouraged.
+• Any record material supporting a motion shall be contained in an appendix with the motion.
+
+
+• Motions concerning preparation of the record or brief, extensions of time (see paragraph 2
+below), or to reschedule oral argument, shall contain a certificate that opposing counsel has
+been consulted and shall state whether opposing counsel has an objection to the motion.
+Attempts to contact opposing counsel are not sufficient.
+• Any response to a motion shall be promptly served, and in any case not later than 15 days after
+service of the motion.
+• Motions for extension of time or to supplement the record may be ruled on without waiting for
+a response.
+• No reply to the response will be considered unless specifically authorized by this Court.
+Any unauthorized reply will be stricken without consideration.
+2. EXTENSIONS OF TIME
+• Limited extensions for briefs can be granted by the Clerk, unless the motion certifies that the
+opposing party opposes the motion and the opposing party files a response which contains a
+valid opposition to the motion.
+• The court may limit extensions in any appeal. See paragraph 1 above for motion requirements.
+• In lieu of an agreed motion for extension of time to file an initial, answer, or reply brief, the
+court will accept a notice from a party that the parties have agreed to a specific extension of
+time. An agreed notice will be accepted for up to a total of 90 days for an initial or answer brief,
+and 15 days for a reply brief. The notice need not be signed by both parties. No order will issue
+from the court: please check the docket entry This procedure shall not apply to appeals from
+adoptions, dependency, termination of parental rights, nonfinal orders, or any expedited or
+emergency appeal. See Administrative Order No. 2018-1 on the court's website for details as to
+the form of the notice.
+•
+Extension requests beyond the time framés set forth above, whether the prior extensions
+were by agreed notice or by order granting an extension, are disfavored and will not be
+granted absent a detailed explanation for why the brief was not filed and a showing of
+extraordinary circumstances.
+3.
+SERVICE OF FILINGS (Fla. R. App. P. 9.420)
+• All filings, e.g., motions, petitions, notices, briefs, appendices, etc., must contain a certificate of
+service. All certificates of service, including those on notices of appeal, must contain the name
+and physical address of the attorney or party served, not just the e-mail address. Certificates of
+service must comply with Florida Rule of General Practice and Judicial Administration 2.516(f).
+4. STATUS INQUIRIES
+• Any request for the status of a pending case must be made to the Clerk's Office and may not be
+de to a judge of the court or the personal staff of any judge. Attorneys and parties
+representing themselves may access case documents and dockets for their own cases via eDCA
+Public case dockets for all cases are available online at 4dca.flcourts.gov.
+RELATED CASES - NOTICE OF RELATED CASE
+• All parties shall promptly bring to the court's attention the pendency in this court of any related
+case, or any case involving related issues.
+• In criminal cases where multiple defendants participated in a joint trial, the parties shall notify
+the court of any other appeals, whether pending or concluded, from the same trial.
+
+
+6. TRANSCRIPTS
+• All transcripts submitted as part of the record must appear as one page of transcript per page.
+Four pane transcripts (four pages of transcript on a page) will be rejected.
+7. PHYSICAL EXHIBITS
+• No physical evidence (excluding documents) or outsized exhibits shall be included in the record
+on appeal without the party first requesting permission of the court. It is the responsibility of
+the party to ensure that the lower tribunal clerk has included any relevant documentary
+evidence introduced at trial in the record on appeal.
+8. SUPPLEMENTAL AUTHORITY (Fla. R. App. P. 9.225)
+• A copy of the newly discovered authority should be attached to the notice. The notice should
+also designate clearly the issue to which the supplemental authority is pertinent. The notice
+shall not contain argument, but may identify briefly the issues argued on appeal to which the
+supplemental authorities are pertinent.
+9. ORAL ARGUMENT (Fla. R. App. P. 9.320)
+• A request for oral argument shall be a separate filing, clearly designated as such, and shall
+contain no other subject. It shall not be made as part of a brief or appendix. The request must
+contain a specific but brief reason as to why oral argument is necessary. A request to
+participate in oral argument through communication technology must be included within the
+request for oral argument and must state the reason why oral argument through
+communication technology is requested‹
+• The request for oral argument may contain a designation of 10, 15 or 20 minutes as the amount
+of time requested for oral argument. Oral argument for each side shall not exceed 20 minutes.
+• At any time before oral argument the court in its discretion may dispense with, limit or expand
+the time for oral argument asit deems appropriate to the issues raised.
+• Cases without oral argument are subject to the same review, analysis and consideration by a
+three judge panel as are cases that are orally argued.
+10. SCHEDULING CONFLICTS
+• Calendar conflicts shall be resolved in accordance with Florida Rule of General Practice and
+Judicial Administration 2.550. "Notices of Unavailability" are unauthorized and will be
+automatically stricken. Requests for continuances of oral argument must be based on either a
+substantial commitment preexisting the receipt of the oral argument calendar or an emergency
+situation.
+11. REHEARING
+• Although motions for rehearing are permitted by Florida Rule of Appellate Procedure 9.330,
+they should be rare. See Lawyers Title Ins. Corp. v. Reitzes, 631 So. 2d 1100, 1100-01 (Fla. 4th DCA
+1993).
+• The court strongly discourages the practice of routinely filing such motions or the filing of those
+which merely re-argue the merits or question the court's decision. Where there has been an
+award of attorney's fees on appeal in connection with our decision on the merits, additional fees
+will be awarded upon a denial of a motion for rehearing.
+
+
+12. RIGHTS OF CHILDREN (Fla. R. App. P. 9.146)
+• Cases involving adoption, termination of parental rights, and those involving families and
+children in need of services are expedited. Consult the rule for the time and procedure
+requirements. Cases relating to child custody, visitation privileges, or other substantial interests
+of children will be expedited upon proper motion.
+13. ATTORNEYS NOT LICENSED IN FLORIDA
+• Attorneys who are members in good standing in other jurisdictions may be granted permission
+by court order to appear in proceedings in this court. See Fla. R. App. P. 9.440(a); Fla. R. Gen.
+Prac. & Jud. Admin. 2.510.
+• Pursuant to Section 35.22(3)(a), Florida Statutes, the Clerk is required to collect a $100 filing fee
+from each attorney appearing pro hac vice, an order for the payment of which will be issued
+when and if the motion to appear is granted. An additional fee of $250 is required by the
+Florida Bar.
+14. MAINTENANCE OF EDCA EMAIL ADDRESSES AND CHANGES OF ADDRESS
+• eDCA users must ensure that their primary and secondary email addresses are up to date.
+• Parties representing themselves who receive paper filings must promptly notify this court of
+any change of address.
+15. DROP BOX
+• The Court does not maintain a physical drop box.
+If you are representing yourself or an
+attorney exempt from electronic filing and would like your paper filing to be clocked-in and
+filed for the previous business day, you must file the document at the Clerk's Office BEFORE
+9:00 A.M. If it is after 9:00 A.M., no filings will be clocked-in for the previous business day.
+• IMPORTANT: The drop box does not extend jurisdictional time limits. See Capone v. Fla. Board
+of Regents, 774 So. 2d 825 (Fla. 4th DCA 2000). Petitions for original writs, notices of appeal, and
+notices to invoke discretionaty jurisdiction will be clocked-in for the date they are electronically
+filed or received as a paper filing in the Clerk's Office.
+16. AMERICANS WITH DISABILITIES ACT
+• If you are a person with a disability who needs any accommodation in order to participate in
+this proceeding, you are entitled, at no cost to you, the provision of certain assistance.
+• At least 2 days before your scheduled court appearance, or immediately upon receiving this
+notification if the time before the scheduled appearance is less than 7 days, please contact:
+Marshal Daniel DiGiacomo
+Fourth District Court of Appeal
+110 South Tamarind Ave.
+West Palm Beach, FL 33401
+Telephone (561) 242-2000; (800) 955-8771 (TDD) or (800) 955-8770 (V) via Florida Relay Service
+If you are hearing or voice impaired, call 711.

vision-fixhub/court-01/0044e94a44ac85296b144a8bccf384cf7452bc2835c7f142bcc02ff96fb6a56c.receipt.json

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vision-fixhub/court-01/005386bdaefe40a8f8f68a91962f8f6dabf3fd1209a43b24b0d62217cba1c73d.md

@@ -0,0 +1,200 @@
+Case 9:09-cv-80469-KAM Document 70 Entered on FLSD Docket 11/16/2009 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/J
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+REPLY TO ROTHSTEIN ROSENFELDT ADLER'S P.A.'S
+RESPONSE TO DEFENDANT'S EMERGENCY MOTION FOR ORDER
+FOR THE PRESERVATION OF EVIDENCE [DE 4051
+(AS TO JANE DOE v. EPSTEIN CASE NO.: 08-CIV- 80893)
+Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned attorneys,
+hereby files his Reply to Rothstein Rosenfeldt Adler P.A.'s ("RRA") Response to
+Defendant's Emergency Motion for Order for the Preservation of Evidence [DE 405],
+and states:
+It now appears that the Honorable Herbert Stettin (Mr. Stettin") is the
+sole individual, as the Chief Restructuring Officer, in charge of RRA assets, including
+electronic and paper records. There also appears to be no objection to the entry of the
+preservation order consistent with his fiduciary/trustee duties for RRA, although certain
+documents may no longer exist within his possession.
+2.
+Par. 4 of the response reflects that some 40 plus boxes of documents were
+obtained by the Department of Justice from search warrants served on the offices of
+
+
+Case 9:09-cv-80469-KAM Document 70 Entered on FLSD Docket 11/16/2009 Page 2 of 5
+RRA; "it is believed that the Department of Justice also sequestered about (13) boxes of
+documents related to this [Epstein] case." In fact there are three Epstein cases which
+have been brought by the RRA firm, one being in federal court, two in state court. Mr.
+Stettin confirms Defendant's belief that there are serious ethical and potentially criminal
+issues that may impact Plaintiffs' ability to pursue their cases.
+3.
+Unfortunately, time is critical with regard to this case in that there are
+deadlines to Disclose Experts and Exchange Reports by October 29, 2009 (but Plaintiff
+has not seen her expert, has no report and only made herself available for the Defendant's
+exam on November 13, 2009), deposition discovery deadline is November 28, 2009 and
+a calendar call of February 19, 2010 for the February 22, 2010 trial docket. While the
+undersigned understands that Mr. Stettin may be working expeditiously to deal with
+critical and pressing needs of stabilizing the firm, a delay of 45 days for his deposition
+(which has been set in the state court case in the 15" Judicial Circuit Court, Palm Beach
+County, State of Florida, L.M. v. Epstein, Case No. 502008CA028051XXXXMB AB,
+not the case sub-judice) will place his deposition sometime during the first 15 days of
+January, after every pre-trial deadline has expired.
+4.
+If in fact there has been inappropriate and/or illegal conduct associated
+with the prosecution of this case by RRA or any of its attorneys or by the Plaintff herself,
+which might result in sanctions, dismissal or other remedy, Defendant Epstein will be
+severely prejudiced.
+WHEREFORE, Defendant Epstein request that the court's preservation order be
+made permanent, which does not seem inconsistent with Mr. Stettin's position as
+expressed by his lawyers but deny the relief sought for delaying the deposition unless the
+
+
+Case 9:09-cv-80469-KAM Document 70 Entered on FLSD Docket 11/16/2009 Page 3 of 5
+court is disposed to modify the current scheduling deadlines and trial date that exist in
+this case.
+By: _
+Robert D. Critton, Jr..
+Florida Bar #224162
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+ROBERT D./CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Brad |
+1 Esq.
+Rothstein Rosenfeldt Adler
+
+
+Case 9:09-cv-80469-KAM Document 70 Entered on FLSD Docket 11/16/2009 Page 4 of 5
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993,
+Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 B, Room 101
+ichard Horace Willits, B
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10" Avenue North
+801-585-6833 Fax
+Suite 404
+Lake Worth, FL 33461
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Isidro M.
+Counsel for Plaintiff in Related Case No.
+Esq.
+Law Firm, P.A.
+08-80811
+224 Datura Street, Suite 900
+reelrhw@hotmail.com
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Counsel for Plaintiffs in Related Cases
+Bruce E. Reinhart, P.A
+Nos. 09-80591 and 09-80656
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+
+
+Case 9:09-cv-80469-KAM Document 70 Entered on FLSD Docket 11/16/2009 Page 5 of 5
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Charles H. Lichtman, Esq.
+Isaac Marcushamer, Esq.
+Berger Singerman, P.A.
+350 East Broward Boulevard, 10" Floor
+954-525-9900
+954-523-2872 Fax
+clichtman@bergersingerman.com
+imarcushamer@bergersingerman.com
+Proposed Attorneys for Alleged Debtor

vision-fixhub/court-01/005386bdaefe40a8f8f68a91962f8f6dabf3fd1209a43b24b0d62217cba1c73d.receipt.json

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vision-fixhub/court-01/00866d2a41e407d40465372d54d2c3dab6f7ee6ba4d9a9bb5d72af8f9d6fa7b8.md

@@ -0,0 +1,75 @@
+Case 1:19-cv-09610-PAE-DCF Document 3 Filed 10/17/19
+AO 440 (Rev. 06/12) Summons in a Civil Action
+UNITED STATES DISTRICT COURT
+for the
+Southern District of New York
+
+JANE DOE 17
+Plaintiffs)
+V.
+Darren K. Indyke and Richard D. Kahn, as Joint
+Personal Representatives of the Estate of Jeffrey E.
+Epstein, Nine East 71st Street Corporation, Laurel,
+Inc., Financial Trust Company, Inc., NES, LLC, et al
+Defendant(s)
+Civil Action No.
+)
+SUMMONS IN A CIVIL ACTION
+To: (Defendant's name and address) DARREN K. INDYKE AND RICHARD D. KAHN, AS JOINT PERSONAL
+REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 71st
+STREET CORPORATION, LAUREL, INC., FINANCIAL TRUST COMPANY, INC.,
+NES, LLC, MAPLE, INC., LSJE, LLC, HBRK ASSOCIATES, INC., NAUTILUS, INC.,
+CYPRESS, INC. and JEGE, INC., c/o Troutman Sanders LLP (NYC), 875 Third
+Avenue, New York, NY 10022
+A lawsuit has been filed against you.
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
+are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
+P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
+the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney,
+whose name and address are: BUZIN LAW, P.C.,111 Broadway, Suite 1204, New York, NY 10006
+WEISMAN, BRODIE, STARR & MARGOLIES, P.A., 1301 N. Federal Highway, Lake
+Worth, FL 33460
+If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
+You also must file your answer or motion with the court.
+CLERK OF COURT
+Date:
+10/17/2019
+Signature of Clerk or Deputy Clerk
+
+
+Case 1:19-CV-09610-PAE-DCF Document 3 Filed 10/17/19 Page 2 of 2
+AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
+Civil Action No.
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (D))
+This summons for (name of individual and title, if any)
+was received by me on (date)
+• I personally served the summons on the individual at (place)
+on (date)
+; or
+• Ileft the summons at the individual's residence or usual place of abode with (name)
+, a person of suitable age and discretion who resides there,
+on (date)
+, and mailed a copy to the individual's last known address; or
+• I served the summons on (name of individual)
+designated by law to accept service of process on behalf of (name of organization)
+on (date)
+; or
+, who is
+• I returned the summons unexecuted because
+• Other (specify):
+; or
+My fees are $
+for travel and $
+I declare under penalty of perjury that this information is true.
+for services, for a total of $
+0.00
+•
+Date:
+Server's signature
+Printed name and title
+Server's address
+Additional information regarding attempted service, etc:
+Print
+Save As...
+Reset

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vision-fixhub/court-01/0086d21b803e3b598e33c957eaa4f57e0e10e5ec80db80e37de42b04e0ae4b0a.md

@@ -0,0 +1,189 @@
+Case 9:08-cv-80380-KAM Document 143-1 Entered on FLSD Docket 07/29/2009 Page 1 of 5
+The Psychological Trauma Center
+a division of Preventive Psychiatry Associates Medical Group, Inc.
+Medical Director: Gilbert W. Kliman, M. D.
+2105 Divisadero St., San Francisco, CA 9411:
+Phone (415)292-7119 Fax (415) 749-2802
+www.experichildpochiatry.com
+Forensic Child Psychiatric Evaluations, Life Care Plans & Testimony
+DECLARATION OF GILBERT KLIMAN, M. D.
+June 4, 2009
+RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES
+IN DOES V JEFFREY EPSTEIN
+1. 1, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California,
+CA. Physicians License G55912, declare the following under penalty of perjury:
+2. I have been retained by plaintiffs' law firm, Mermelstein & Horowitz, to give expert
+testimony. If called as a witness, I would testify truthfully and competently concerning
+my psychiatric findings about each of the plaintiffs' alleged experiences of sexual abuse,
+and the enduring effects that I find each of the young women have suffered as a direct
+result of the sexual acts perpetrated by the defendant.
+3. I have been asked to respond to the Defense motion, which requests that some of the
+plaintiffs, who are now adults, should be publicly named. It is my opinion that
+involuntary public disclosure will result in the plaintiffs experiencing revictimization,
+albeit by a justice system that is designed to protect them. If their identities are released,
+the victims will be at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media
+and general public. This type of exposure humiliates many victims and represents anothe
+betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization
+4. Due to traumatization the plaintiffs are arrested in their development, and even those
+who are now legally adults are arrested in part to adolescent aspects of psychology.
+5. The plaintifts do not hold their heads high with pride for having been sexually
+absorption and self-doubt and self-blame about sexual acts.
+
+A
+1
+
+
+Case 9:08-cv-80380-KAM Document 143-1 Entered on FLSD Docket 07/29/2009 Page 2 of 5
+6. Clinically harmful levels of shame, self-consciousness, self-doubt and self-blame are
+even more prominent among victims of molestations than among the general population.
+7. Molested teenagers are particularly vulnerable to wrongful manipulations and special
+clinical harms from the experiences of shame and humiliation. In fact, shame and efforts
+to cope with it played an underlying role in the harm to each plaintiff. Each was lured
+into Mr. Epstein's sexual lair with the promise of overcoming bodily and sexual shame
+by earning money and bettering their lot in life. The defendant capitalized on their sexual
+naiveté, insecurities and effort to better themselves, and he worked hard to overcome
+their shame at his enlistment of them in his selfish gratifications.
+8. The defendant who wishes to make their identities public is one whom the criminal
+justice system has already determined is a person who has already committed a crime of
+child molestation. That surely means he has already exploited and manipulated the girls'
+state of adolescent sexuality, including their embarrassment, awkwardness and bodily
+self-consciousness. He perverted their nascent and developing moral structures by posing
+as a generous, avuncular mentor who could coach them about their bodies, sex and love.
+The exploitation of adolescent bodies, sex and love is - from a psychoanalytic point of
+view - an influence on the developing moral conscience of the children, as well as on
+their sexual urges. Now the ravaging of their internal and private moral conscience is
+intended by the perpetrator to be made a public ravaging.
+9. Among sexual trauma victims, the insidious and destructive persistence of shame,
+humiliation and associated self-blame is well-documented (Finkelhor and
+_, 1985).
+Stigmatization, as experienced by a sexual trauma victim, has especially painful and
+pathologic consequences. Shame lingers and becomes integrated within the adolescent
+victim's malleable emerging identity, character structure and self image. Moral clarity is
+distorted, Perceptions of self-blame and guilt are magnified. The impact of shame lends
+to cultivating a self image of being "spoiled goods."
+10. Stigmatization following sexual trauma results in long-term risks that can negatively
+shape multiple facets of adult development: sexual, emotional, interpersonal and
+vocational. Stigmatization, which is generally to be avoided among psychiatric patients,
+ncreases risks among those — as in our plaintifts as a group - who experience clinical
+epression and self-destructive behaviors: drug use, criminal activity, even prostitution
+Stigmatization following abuse is associated with delinquency due to increased anger
+and affiliation with deviant peers (Feiring et al., 2007).
+11. Shame and guilt are important dimensions of both complex and single event,
+posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of
+helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in
+relation to Mr. Epstein.
+
+
+Case 9:08-cv-80380-KAM Document 143-1 Entered on FLSD Docket 07/29/2009 Page 3 of 5
+12. The DSM-IV-TR recognizes both powerlessness and helplessness as requisite parts of
+the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder
+Seligman, recent Past President of the American Psychological
+Association, coined relevant terms of "learned helplessness and "Loss of Personal Locus
+of Control." See Seligman, M.P. 1975: Helplessness, Depression, Development and
+Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal
+locus of control to a much more experienced, sexually aggressive, powerful and
+dominant, manipulative perpetrator.
+13. Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of'
+posttraumatic stress disorder trauma. In effect, release of their identity and public
+intrusion into their personal life represents a reenactment of the shame of sexual
+traumatization. Repetition and reenactment are central pathologies that afflict sexual
+trauma survivors.
+14. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial,
+as a detensive means to manage overwhelming attects associated with the sexual trauma.
+Each of the plaintiff girls has employed some variation of this defense, both during the
+massages and then subsequently following disclosure of the abuse. Primitive,
+maladaptive responses of this nature will become additionally reinforced as a result of
+public disclosure.
+15. Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, is
+that the trauma was associated with human design factors (such as cruel intention to do
+harm, rape, torture). Trauma of this origin has a tendency to produce more "severe or
+long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A
+policy of deliberate revelation of the names of the victims would reinforce the sense of
+design, pattern and policy of human intentions.
+16. Negative expectations about significant activities are noted in DSM-IV-TR, as part of
+Criterion C. Symptoms of foreshortened future are characteristic of a traumatized
+individual's clinical course (C4). They expect revictimization. They expect bad outcomes
+identity will aggravate existing symptoms of hypervigilance.
+17. The DSM-IV-TR diagnostic category of "chronic" is justified for each of the
+auntills. Scientifie literature shows that the prognostic consequences of PTSD an
+esidual effects may last for decades (U.S. Dept. of Health, 2005; Issues in Child Abus
+Prevention Number 9 Autumn1998: Long-term Effects of Child Sexual Abuse, Paul E
+Mullen and Jillian Fleming). The lasting impact upon character, identity and moral
+development will probably affect long-term influences upon adult development. It is
+more probable than not that stigmatization associated with public disclosure of the
+3
+
+
+Case 9:08-cv-80380-KAM Document 143-1 Entered on FLSD Docket 07/29/2009 Page 4 of 5
+plaintiffs' identities will intensify the scope, nature and severity of the chronic symptom
+course.
+18. In addition to PTSD, shame and humiliation themselves have also been associated
+with causing clinical depression. Coexisting PTSD and clinical depression places the
+plaintiff's at increased risk for re-victimization and high risk sexual behaviors (e.g.,
+sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater
+risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control,
+2002) who are in their control. Studies have also shown that chronic symptoms of PTSD,
+in association with a single episode of Major Depressive Disorder, can produce lifetime
+additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and
+humiliation associated with public disclosure of their identities.
+19. Alternative hypothesis: I have applied the evidence shown from examination and
+testing of the plaintiffs and relevant observations and information from other
+professionals while testing an alternative hypothesis: that no harm would result from
+public disclosure of the plaintiffs' identities. During the evaluations with the six
+plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR
+disorder occurred. I established that there were provable and diagnosable injuries,
+primarily posttraumatic stress disorder and comorbid depression. Based upon these
+diagnostic signs, it is more probable than not, that exposing the plaintiff's identity to the
+public is not a trivial concern or one without substantial clinical repercussions. I believe
+that most child, adolescent and adult psychiatrists would share the opinion that additional
+psychiatric injury will result from such exposure.
+20. However, consider for the sake of argument, that my diagnostic conclusions are
+incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of
+taking a history from multiple sources, videotaping and transcribing my initial interview,
+and reviewing available medical and legal documents. Even if this was the case, and my
+diagnostic conclusions were faulty, I believe that multiple experts, even those who may
+now propose publication of the victims' names, would still come to a conclusion that the
+plaintiff's suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the
+hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much
+clinical evidence and scientific literature showing likelihood of substantial psychiatric
+harm to these sexually abused plaintiffs.
+21. To form these conclusions, I have used my extensive experience in forming these
+opinions. That experience is both as a treating child psychiatrist and separately as a
+forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally
+evaluated hundreds of children and adolescents who have suffered sexual abuse. I have
+made long term followups of many of the children and have treated many adults who
+have been molested as adolescents. It is my opinion, with a reasonably high degree of
+medical certainty that the defense motion to allow public disclosure of the plaintiffs'
+identities is clinically and ethically a wrongful plan. The act of revealing their identities
+against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
+4
+
+
+Case 9:08-cV-80380-KAM Document 143-1 Entered on FLSD Docket 07/29/2009 Page 5 of 5
+an aggravation of existing diagnostic concerns. It is more probable than not that releasing
+personal identities will f
+an exacerbation and magnification of symptoms lending to
+increased risk of revictimization and retraumatization.
+I declare under penalty of perjury under the laws of the State of California that the
+foregoing statements are true and correct, and that this declaration was executed at San
+Francisco, California on June 4, 2009.
+Sincerely
+Gilbert Kliman, M.D.
+Distinguished Life Fellow, American Psychiatric Association
+Senior Fellow, American Academy of Child and Adolescent Psychiatry
+Brockman Award Holder, for Distinguished Lifetime Contributions to
+Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and
+Psychiatry
+LEONID NAKHODKIN
+Соми. # 1791115
+NOTARY PUBLIC- CALIFORMA
+DITY & COUNTY OF SAN FRANCISO
+ty Cow. Exp. FEe: 27, 2012 H
+State of California, City & County of San Francisco
+subscibed and sworn to (or attimed) before me on the
+a cay of undog by Gilbert Klinken
+proved me petrol shoppered peter me
+5

vision-fixhub/court-01/0086d21b803e3b598e33c957eaa4f57e0e10e5ec80db80e37de42b04e0ae4b0a.receipt.json

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vision-fixhub/court-01/00aa9b07b0aa010948b3e7477b63165e1129627ebfd6e953bf510b607650c6dc.md

@@ -0,0 +1,54 @@
+Case 1:20-cv-00484-JGK-DCF Document 93-2 Filed 01/29/21 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+X
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of
+the ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual,
+Defendants.
+20-cv-00484-JGK
+Proposed Order
+JOHN G. KOELTL, United States District Judge:
+This matter is before me on Plaintiff's Motion to Dismiss With Prejudice Pursuant to
+FRCP 41(a)(2) of the Federal Rules of Civil Procedure and Ms. Maxwell's Response thereto.
+It is hereby ORDERED that, pursuant to Rule 41(a)(2) of the Federal Rules of Civil
+Procedure, the above-captioned action will be dismissed with prejudice, upon the following
+conditions:
+Plaintiff shall provide an unredacted and signed copy of the General Release she
+executed with the Epstein Victims' Compensation Program ("EVCP") within two (2) business
+days of her affirmative acceptance of the conditions set forth herein, or the expiration of the time
+period for withdrawing her Motion to Dismiss, as set forth below, together with a certification of
+its authenticity;
+Plaintiff and Darren K. Indyke and Richard D. Kahn, in their capacities as executors of
+the Estate of Jeffrey E. Epstein, shall each bear their own attorneys' fees and costs of suit.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 93-2 Filed 01/29/21 Page 2 of 2
+Nothing herein shall be construed to preclude Ms. Maxwell from seeking fees or costs
+related to this matter from plaintiff or from the Estate of Jeffrey E. Epstein, Darren K. Indyke, in
+his capacity as Executor of the Estate of Jeffrey E. Epstein, Richard D. Kahn, in his capacity as
+Executor of the Estate of Jeffrey E. Epstein, or NES, LLC, a New York Limited Liability
+Company, or release any such claims as between the Defendants. Nor does anything herein
+prejudice the Estate Of Jeffrey E. Epstein, Darren K. Indyke, in his capacity as Executor of the
+Estate Of Jeffrey E. Epstein, Richard D. Kahn, in his capacity as Executor of the Estate Of
+Jeffrey E. Epstein, or NES, LLC's rights and legal positions with respect to Ms. Maxwell's
+seeking of fees or costs related to this matter, all of which rights and legal positions are hereby
+expressly preserved.
+It is further ORDERED that plaintiff shall have until L
+_] to accept an
+Order of Dismissal with Prejudice on the above terms, or withdraw her MOTION TO DISMISS
+WITH PREJUDICE PURSUANT TO FRCP 41(a)(2) filed January 15, 2020. If Plaintiff
+takes no action by L
+_], the conditions will be deemed accepted, and this Order and
+Judgment including the conditions shall be entered forthwith.
+Dated: New York, New York
+_. 2021
+SO ORDERED
+JOHN G. KOELTL
+United States District Judge
+Southern District of New York
+1

vision-fixhub/court-01/00aa9b07b0aa010948b3e7477b63165e1129627ebfd6e953bf510b607650c6dc.receipt.json

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vision-fixhub/court-01/00cccc511e442c139c4ad905d8fb1eb276bafe7d6fb61a832bb37ad8d0360314.md

@@ -0,0 +1,78 @@
+Case 9:08-cV-80119-KAM Document 4 Entered on FLSD Docket 05/22/2008 Page 1 of 1
+Form 42 - DOORMAN WITH MILITARY
+HERMAN & MERMELSTEIN PA
+ATTN: LISA
+U.S. SOUTHERN COURT
+FLORIDA • COUNTY
+Index No. 08CV80119MARRA-
+JANE DOE NO.2
+plaintiff
+Date Filed
+- against -
+Office No.
+JEFFREY EPSTEIN
+defendant
+Court Date:
+/ /
+STATE OF NEW YORK, COUNTY OF NEW YORK
+: SS:
+HARRY
+being duly sworn, deposes and says; I am over 18 years
+of age, not a party to this action,
+and reside in the State of New York. That on the
+7th day of May,
+2008 07:45 AM
+at
+9 EAST 71ST ST
+NEW YORK, NY 10021
+I served the SUMMONS AND COMPLAINT
+after prior attempts were made on: 04/23/2008 06:15 PM 04/24/2008 02:30 PM 05/01/2008 06:27Pg
+upon JEFFREY EPSTEIN
+**
+the DEFENDANT therein named by delivering and leaving a true copy or copies
+of the aforementioned documents with
+"JOHN
+", ASSISTANT & HOUSE STAFF EMPLOYEE WHO
+REFUSED TRUE NAME
+a person of suitable age and discretion, who refused access to DEFENDANT' s
+actual apartment, and accepted in accordance with his/her everyday duties.
+Deponent describes the person served as aforesaid to the best of deponent's ability
+at the time and circumstances of the service as follows:
+SEX: MALE
+COLOR:
+HAIR:
+AGE: 45 HEIGHT: 6:0 WEIGHT: 200
+OTHER IDENTIFYING FEATURES: MUSTACHE/BEARD
+0n---f--f-----I -depesited-in the United States mail a true copy of-the afarenenț ioned-
+- documents _properly enclosed and sealed-in a post-paid wrapper-adressed to-the-said -
+DEFENDANI at-the above address- That-address being
+last known residenco, usual placa of abode of the DERENDANI.
+Copy mailed dat-alass nail-marked porsenal «-confidentiał -not-indicating- en the-eutoide thereof--
+→y-Fatia-adress Di-otherwiso that taid totica is-from- at atterney-or coneer-actien-agatast
+the-person to be served. **& 5/5/08 9:20PM
+That at the time of service as aforesaid, I asked person spoken to whether DEFENDANT
+was in the military service of the State of New York or United States and received a negative
+ais elon and bo toe bard of a toa
+reply. Upon information and belief based upon the conversation and observation as aforesaid
+I aver that the DEFENDANT is not in the military service of the State of New York or the
+United States as that term is defined in the statutes of the State of New York or the Federal
+Soldiers and Sailors Civil Relief Act.
+DEPONENT STATED AT THE TIME OF SERVICE HE HAD LEGAL PAPERS
+IN A FLORIDA ACTION.
+Sworn to before me /this
+12th day oi May,
+2008ni
+SAMSON
+Notary Public,
+New York
+No.01NE-4783767
+Qualified in NEW YORK COUNTY
+Commission Expires 11/03/2009
+HARRY TORRES
+091$25
+AETNA
+'CENTRAL JUDICIAL
+225 BROADWAY, SUITE 1802
+NEW YORK, NY, 10007
+Reference No: 7HM4111728
+SERVICES

vision-fixhub/court-01/00cccc511e442c139c4ad905d8fb1eb276bafe7d6fb61a832bb37ad8d0360314.receipt.json

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vision-fixhub/court-01/00d6dbce0957b5d663ddbac587ab9e5e61a7f3b97b4c405612958014932d4dab.md

@@ -0,0 +1,48 @@
+From:
+Subjecti
+BACE:
+Filling 197366740 Processed - Appellate Courts
+Wadranday, May 1, 2024 11:02:16 AM
+Dear Palm Beach County - BRENT T ROBBINS:
+This email verifies the processing of your Brief/Record Record On Appeal by the Office of the Clerk, Fourth District Court of
+Appeal.
+Status: Docketed
+Florida Courts E-Filing Portal Reference Number: 197366740
+Filing Date/Time: 05/01/2024 10:15:27 AM
+Case Number: 4D2024-0681
+Documents
+#
+1
+Document Type
+Status
+Brief/Record Record On Appeal Accepted
+Fees
+Description
+Subsequent Filing Fee - APPEAL
+Regarding Circuit Civil Matters Other
+2 Brief, Record On Appeal
+Memo:
+Statutory Convenience Fee: $0.00
+Total Paid: $0.00
+Fee Status: Processed
+Paid By: No payment required
+Order #:
+Filing Date Not Docketed Reason
+05/01/2024
+Your Attachment
+Amount
+$.00
+$.00
+IRTIFIED CO
+2019CA014681XXXXMB-
+Récord - XX,pdf
+Financial ID:
+Please be sure to register for your Appelfate Case Information System (ACIS) account. For information on registering
+please visit https://www.flcourts.gov/ACIS.
+This is a non-monitored email. If you have questions about this filing, please contact the Office of the Clerk, Fourth District
+Court of Appeal, at (561) 242-2000.
+Thank you,
+Office of the Clerk
+Fourth District Court of Appeal
+FILED: PALM BEACH COUNTY, FLI
+•ABRUZZO, CLERK 05/01/2024 11:02:46 AM

vision-fixhub/court-01/00d6dbce0957b5d663ddbac587ab9e5e61a7f3b97b4c405612958014932d4dab.receipt.json

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vision-fixhub/court-01/00ee20accb0c270afd4dc0ccf77c8c3b6d833b48c15cc4dd49e79a519691e78e.md

@@ -0,0 +1,137 @@
+Case 9:08-cv-80736-KAM Document 205 Entered on FLSD Docket 07/05/2013 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA/MATTHEWMAN
+JANE DOE #1 AND JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES,
+Respondent.
+UNITED STATES' NOTICE OF FILING
+Pursuant to the Court's June 18, 2013, Order Granting Petitioners" Motion to Require
+Government to File Redacted Pleadings in the Public Court File, the Respondent hereby gives
+notice of its filing of the unsealed/redacted versions of filings previously made under seal by the
+government, as listed in the following table:
+Appendix
+A
+Original
+Docket #
+118
+119
+C
+D
+120
+121
+E
+146
+F
+147
+Filing Date
+Filing
+11/07/2011
+11/07/2011
+11/07/2011
+11/07/2011
+Motion to Seal United States' Motion to Dismiss for
+Lack of Subject Matter Jurisdiction
+United States' Sealed Motion to Dismiss for Lack of
+Subject Matter Jurisdiction
+Motion to Seal Respondent's Motion to Stay Discovery
+Pending Ruling Upon Respondent's Motion to Dismiss
+Respondent's Sealed Motion to Stay Discovery Pending
+Ruling Upon Respondent's Motion to Dismiss
+Motion to Seal United States' Reply in Support of Its
+01/26/2012
+Motion to Dismiss for Lack of Subject Matter
+Jurisdiction
+01/26/2012
+United States' Reply in Support of Its Motion to
+Dismiss for Lack of Subject Matter Jurisdiction
+Those filings are contained in the appendix to this notice as indicated in the foregoing table.
+
+
+Case 9:08-cv-80736-KAM Document 205 Entered on FLSD Docket 07/05/2013 Page 2 of 3
+Respectfully submitted,
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+By: Is Dexter A. Lee
+Dexter A. Lee
+Assistant United States Attorney
+Florida Bar No. 0936693
+99 N.E. 4th Street
+Miami, Florida 33132
+Tel: (305) 961-9320; Fax: (305) 530-7139
+Email: dexter.lee@usdoj.gov
+Eduardo I.
+Assistant United States Attorney
+Florida Bar No. 877875
+99 N.E. 4th Street
+Miami, Florida 33132
+Tel: (305) 961-9057; Fax: (305) 536-4676
+Email:
+A.
+Villafaña
+Assistant United States Attorney
+Florida Bar No. 0018255
+500 S. Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Tel: (561) 820-8711; Fax: (561) 820-8777
+Email:
+Attorneys for Respondent
+CERTIFICATE OF SERVICE
+I hereby certify that a true and correct copy of the foregoing United States' Notice of
+Filing was served via CM/ECF on this 5th day of July, 2013, on the parties and counsel
+appearing on the attached service list.
+Is Dexter A. Lee
+Assistant United States Attorney
+2
+
+
+Case 9:08-cv-80736-KAM Document 205 Entered on FLSD Docket 07/05/2013 Page 3 of 3
+SERVICE LIST
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/MATTHEWMAN
+United States District Court, Southern District of Florida
+Brad
+Esq.,
+-Jaffe, Weissing,
+, Fistos & Lehrman, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+(954) 524-2820
+Fax: (954) 524-2822
+E-mail: brad@pathtojustice.com
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+(305) 371-6421
+Fax: (305) 358-2006
+E-mail: pleading@royblack.com
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+Attorneys for Jane Doe # 1 and Jane Doe #2
+G. Weinberg
+G. WEINBERG, P.C.
+20 Park Plaza
+Suite 1000
+Boston,
+02116
+Office: (617) 227-3700
+Fax: (617) 338-9538
+Email: owlmgw@att.net
+Jay P. Lefkowitz
+Kirkland &Ellis, LLE
+501 Lexington Avenue
+New York, NY 10022
+212-446-4970
+Fax: 212-446-4900
+Email: lefkowitz@kirkland.com
+3

vision-fixhub/court-01/00ee20accb0c270afd4dc0ccf77c8c3b6d833b48c15cc4dd49e79a519691e78e.receipt.json

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vision-fixhub/court-01/00ef8b84ed0f721b3724a79dd029e3aaa3e2e6fc583e7d1001a9666457bc08a7.md

@@ -0,0 +1,187 @@
+Case 9:08-cv-80119-KAM Document 450-3 Entered on FLSD Docket 01/13/2010 Page 1 of 2
+0001
+1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+2
+CASE NO.: 08-CIV-80119-MARRA
+3
+4
+5
+6
+7
+8
+JANE DOE NO. 2,
+Plaintiff,
+-VS-
+JEFFREY EPSTEIN,
+Defendant.
+9
+10
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+11
+12
+14
+15
+16
+VIDEO-TELECONFERENCED AND VIDEOTAPED
+COMPULSORY MEDICAL EVALUATION OF
+JANE DOE NO. 3
+Tuesday, November 24, 2009
+9:18 - 4:45 p.m.
+17
+18
+19
+250 Australian Avenue
+Suite 1500
+West Palm Beach, Florida 33401
+20
+21
+22
+23
+24
+'vnthia
+1, RPR, FPR
+Notary Public, State of Florid
+Prose Court Reporting Services
+25
+0002
+1
+APPEARANCES:
+2
+On behalf of the Plaintiff:
+3
+JESSICA D. ARBOUR, ESQUIRE
+MERMELSTEIN & HOROWITZ, P.A.
+4
+18205 Biscayne Boulevard
+Suite 2218
+5
+Mone:, 505.93.22060
+305.931.2200
+6
+E-mail: Ahorowitz@sexabuseattorney.com
+8
+9
+10
+11
+12
+ALSO PRESENT:
+Dr. Ryan
+T. M.D.
+Paralegal,
+Burman, Critton, Luttier & Coleman
+EXHB "C"
+-91030Settinoe/Prodnetion/Desktop/Doe%20No.%203,%20Jane%20-%20Vol.%20I.txt[1 1/30/2009 1:28:26 PM]
+
+
+Case 9:08-cv-80119-KAM Document 450-3 Entered on FLSD Docket 01/13/2010 Page 2 of 2
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+0192
+1
+2
+A. I told them exactly what could happen.
+Q. Give me -- I mean, what did you tell them?
+A. I told them that I got a phone call from Haley
+that this guy is flying into town. He likes to get
+massages, this is what could happen, do you want to do
+it?
+Q. Okay.
+A. So they --
+Q. Did you have to invite them?
+A. Did I have to invite them?
+Q. Yeah. Did you have to tell them?
+A. I don't think anyone has to do anything.
+Q. Okay. So, it wasn't that you had no
+control over inviting them?
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+0193
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+A. I still don't understand that, the way that
+you're saying it, it's not -- I'm, I'm just maybe not
+comprehending.
+Q. I mean, you weren't worried that he was
+going to beat you up, have you arrested, have you
+killed if you didn't bring more people?
+A. I didn't know what, I didn't know what he
+could have done. To be honest with you, my honest
+opinion, a man of that stature --
+Come in. Come in.
+THE VIDEOGRAPHER: Sorry for the
+interruption. I just need to change the tape.
+DR.
+Change the tape.
+(A brief recess was held from 4:29 p.m.
+until 4:33 p.m.)
+MS. ARBOUR: I just want to make the
+record that it is 4:35, and we are going to be
+terminating this IME because my client and I
+went downstairs. Jane Doe 3 and I went
+downstairs. We ran into Jeffrey Epstein who is
+present in the building and in violation of
+three court orders. He made direct eye contact
+with me and obviously to me appeared to have
+recognized me. I did my best to shield my
+client, but obviously there was a moment of
+contact and she is now crying hysterically and
+unable to compose herself. So, we're going to
+go. And that's my record.
+(A brief recess was held from 4:36 p.m.
+until 4:42 p.m.)
+THE VIDEOGRAPHER: Okay. We're on.
+MS. ARBOUR: One more thing I wanted to
+add is that Mr. Epstein was dressed in a gray
+sweatsuit and his building or his office of the
+Florida Science Foundation is no longer in this
+building, so it is unclear to me what he is
+doing here. Thank you.
+(Compulsory Medical Evaluation was
+6l11/Mormente Nand%20Settines/Production/Desktop/Doe%20No.%203,%20Jane%20-%20Vol.%201.txt[|1/30/2009 1:28:26 PM]

vision-fixhub/court-01/00ef8b84ed0f721b3724a79dd029e3aaa3e2e6fc583e7d1001a9666457bc08a7.receipt.json

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+}

vision-fixhub/court-01/00f0a7913cd8edd51e07989f31dcf341f497e8deece36b6522963ab7cd5ee840.md

@@ -0,0 +1,164 @@
+Case 1:19-cv-10577-LJL-DCF Document 29 Filed 02/14/20 Page 1 of 2
+JANE DOE 1000,
+X
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN in their capacities as the executors of
+the ESTATE OF JEFFREY EDWARD
+EPSTEIN,
+Index No. 1:19-cv-10577-LGS-DCF
+Defendants.
+.7--
+X
+MOTION FOR ADMISSION PRO HAC VICE
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and
+Eastern Districts of New York, Molly S. DiRago hereby moves this Court for an Order for
+admission to practice Pro Hac Vice to appear as counsel for Darren K. Indyke and Richard D.
+Kahn as Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the
+above-captioned action.
+I am in good standing of the bar(s) of the state of Illinois and there are no pending
+disciplinary proceedings against me in any state or federal court. I have never been convicted of
+a felony. I have never been censured, suspended, disbarred or denied admission or readmission
+by any court. I have attached the affidavit pursuant to Local Rule 1.3.
+
+
+Case 1:19-cv-10577-LJL-DCF Document 29 Filed 02/14/20 Page 2 of 2
+Dated: February 14, 2020
+Respectfully Submitted,
+Is/ Mary "Molly" S. DiRago
+Mary "Molly" S. DiRago (Pro Hac Vice Pending)
+Troutman Sanders LLP
+One North Wacker Drive, Suite 2905
+Chicago, 60606
+(312) 759-1926
+(312) 759-1939 (Fax)
+molly.dirago@troutman.com
+Attorneys for Defendants Darren K. Indyke and
+Richard D. Kahn, Co-Executors of the Estate of
+Jeffrey E. Epstein
+
+
+Case 1:19-cv-10577-LJL-DCF Document 29-1 Filed 02/14/20 Page 1 of 2
+JANE DOE 1000,
+X
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN in their capacities as the executors of
+the ESTATE OF JEFFREY EDWARD
+EPSTEIN,
+Index No. 1:19-cv-10577-LGS-DCF
+Defendants.
+X
+AFFIDAVIT IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
+I, Mary "Molly" S. DiRago, declare as follow:
+I am a member in good standing of the State Bar of Illinois and an associate with
+the law firm Troutman Sanders LLP, counsel for Defendants, Darren K. Indyke and Richard D.
+Kahn as Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"). I submit
+this affidavit in support of my Motion for Admission Pro Hac Vice before this Court.
+2.
+I have never been convicted of a felony.
+3.
+I have never been censured, suspended, disbarred, or denied admission or
+readmission by any court.
+4.
+There are no disciplinary proceedings presently against me.
+I declare under penalty of perjury under the laws of the United States of America that the
+foregoing is true and correct.
+
+
+Case 1:19-cv-10577-LJL-DCF Document 29-1 Filed 02/14/20 Page 2 of 2
+Dated: February 14, 2020
+Respectfully Submitted,
+Is/ Mary "Molly" S. DiRago
+Mary "Molly" S. DiRago (Pro Hac Vice Pending)
+Troutman Sanders LLP
+One North Wacker Drive, Suite 2905
+Chicago, 60606
+(312) 759-1926
+(312) 759-1939 (Fax)
+molly.dirago@troutman.com
+Attorneys for Defendants Darren K. Indyke and
+Richard D. Kahn, Co-Executors of the Estate of
+Jeffrey E. Epstein
+
+
+Case 1:19-cv-10577-LJL-DCF Document 29-2 Filed 02/14/20
+
+Certificate of Admission
+To the Bar of Illinois
+1, Carolyn Taft Grosboll, Clerk of the Supreme Court of illinois, do hereby certify that
+Mary Sharon DiRago
+as eh duly licensad a has miled ta practice required ray no Gupolorat
+CONSTITUTION OF THE UNITED STATES and of the STATE OF ILLINOIS, and
+also the oath of office prescribed by law, that said name was entered upon the Roll
+of Attorneys and Counselors in my office on 11/04/2004 and is in good standing, so
+far as the records of this office disclose.
+IN WITNESS WHEREOF, 1 have hereunto
+subscribed my name and affixed the
+seal of said Court, this 31st day of
+January, 2020.
+Cardya Taft Gosboll
+Clerk,
+Supreme Court of the State of Illinois
+
+
+Case 1:19-cv-10577-LJL-DCF Document 29-2 Filed 02/14/20 Page 2 of 2
+CERTIFICATE OF GOOD STANDING
+VIS CELINA
+DOVEL TO BUTTE
+United States of America
+Northern District of Illinois
+}ss. Mary S DiRago
+1, 1
+G. Bruton, Clerk of the United States District Court
+for the Northern District of Illinois,
+DO HEREBY CERTIFY That Mary S DiRago
+was duly admitted to practice in said Court on (12/08/2004)
+and is in good standing as a member of the bar of said court.
+Dated at Chicago, Illinois
+on (01/29/2020 )
+G. Bruton, Clerk,
+By: Tina Lam
+Deputy Clerk
+
+
+Case 1:19-cv-10577-LJL-DCF Document 29-3 Filed 02/14/20 Page 1 of 2
+JANE DOE 1000,
+X
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN in their capacities as the executors of
+the ESTATE OF JEFFREY EDWARD
+EPSTEIN,
+Index No. 1:19-cv-10577-LGS-DCF
+Defendants.
+• X
+ORDER FOR ADMISSION PRO HAC VICE
+The motion of Mary "Molly" S. DiRago for admission to practice Pro Hac Vice in the
+above captioned action is granted.
+Applicant has declared that she is a member in good standing of the bar(s) of the state(s)
+of Illinois; and that her contact information is as follows:
+Mary "Molly" S. DiRago
+Troutman Sanders LLP
+One North Wacker Drive, Suite 2905
+Chicago, 60606
+(312) 759-1926
+(312) 759-1939 (Fax)
+molly.dirago@troutman.com
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for
+Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein
+(together, the "Co-Executors"), in the above entitled action;
+IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the
+above captioned case in the United States District Court for the Southern District of New York.
+1
+
+
+Case 1:19-cv-10577-LJL-DCF Document 29-3 Filed 02/14/20 Page 2 of 2
+All attorneys appearing before this Court are subject to the Local Rules of this Court, including
+the Rules governing discipline of attorneys.
+Dated:
+United States District/Magistrate Judge
+2

vision-fixhub/court-01/00f0a7913cd8edd51e07989f31dcf341f497e8deece36b6522963ab7cd5ee840.receipt.json

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vision-fixhub/court-01/01123d790d13f397473f6d922cfd4a0d6b4df1e128a8eceab263af79d112e416.md

@@ -0,0 +1,39 @@
+Case 1:20-cv-00484-JGK-DCF Document 48 |
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman.com
+Filed 06/24/20 Page 1 of 1
+troutman"
+sanders
+Bennet J. Moskowitz
+D: 212-704-6000
+bennet.moskowitz(@troutman.com
+June 24, 2020
+Via ECF
+Hon. John G. Koeltl
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl St.
+New York, NY 10007-1312
+Re:
+Jane Doe v. Darren . Indyke and Richard D. Kahn, in their capacities as coexecutors of the Estate of Jeffrey E. Epstein, and Ghislaine Maxwell, an individual,
+1:20-cv-00484-JG -DCF
+Dear Judge Koeltl:
+We represent Defendants Darren _. Indyke and Richard D. Kahn, Co-Executors of the Estate of
+Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced action. We write to
+further supplement the Co-Executors' pending motion to dismiss (ECF Doc. 36) with the
+enclosed Opinion & Orders entered in two other personal injury actions against the Co-
+Executors. The first was entered earlier this month by The Hon. Edgardo Ramos in Lisa Doe v.
+Darren i. Indyke and Richard D. Kahn, as Joint Personal Representatives of the Estate of
+Jeffrey E. Epstein, et al. (19-cv-07773 (ER) (DCF)). The second was entered yesterday by The
+Hon. Katherine Polk Failla in Jane Doe v. Darren . Indyke and Richard D. Kahn, in their
+capacities as co-executors of the Estate of Jeffrey E. Epstein (19-cv-08673 (KPF) (DCF)). In
+both Opinion & Orders, the sister courts grant the Co-Executors' motions to dismiss the
+plaintiffs' punitive damages claim against them as a matter of law on grounds applicable to
+Plaintiff's claim for punitive damages in this action.
+Respectfully submitted
+s/Bennet J. Moskowitz
+Bennet J. Moskowitz
+cc: Counsel of Record (via ECF)

vision-fixhub/court-01/01123d790d13f397473f6d922cfd4a0d6b4df1e128a8eceab263af79d112e416.receipt.json

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vision-fixhub/court-01/01225f76c24db412c8b6f1e180f0c266530ec6b7cdef32befa8c7c9653376ef0.md

@@ -0,0 +1,426 @@
+Case 9:08-cv-80119-KAM Document 319-3 Entered on FLSD Docket 09/22/2009 Page 1 of 8
+Page 1
+IN RE:
+JEFFREY EPSTEIN
+TAPED INTERVIEW
+ORIGINAL
+Sandy
+Notary Public, State of Florida
+Consor and Associates
+Phone - 561.682.0905
+"C"
+
+
+Case 9:08-cv-80119-KAM Document 319-3 Entered on FLSD Docket 09/22/2009 Page 2 of 8
+Page 2
+(Thereupon, the following interview was had:)
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY DETECTIVE RECAREY:
+Today's date is October 4th, 2005. This is ID
+number 7915 Detective Joe Recarey of the Palm Beach Police
+Department. Present at 1301 (inaudible) Road is Detective
+Michael Dawson of the Palm Beach Police Department.
+And can you state your name for the record?
+A
+how do you spell your last name?
+A
+A
+Okay.
+How old are you?
+I'm 18.
+Eighteen. Okay. You're currently in college?
+A
+Yeah.
+Okay. What college are you attending?
+A
+Valencia.
+Valencia. Okay.
+And your date of birth is?
+A
+Q
+Okay. Can you raise your right hand for me? Do
+you solemnly swear to tell the truth, the whole truth and
+nothing but the truth so help you God?
+Yes.
+• Okay.
+if you could tell me from the
+beginning how you met Jeffrey Epstein. I know you have some
+
+
+Case 9:08-cv-80119-KAM Document 319-3 Entered on FLSD Docket 09/22/2009 Page 3 of 8
+Page 3
+1
+information and we are conducting an investigation. We were
+2
+here last night, spoke with your mom and dad. If you can
+3
+just start from the beginning as to how you met him.
+4
+A Okay.
+5
+And how it came about.
+6
+A
+I met him through my friend Haley.
+7
+Okay. How long ago was that?
+8
+A
+It was probably about almost a year ago.
+9
+Okay. Okay.
+And he -- I went there once with her and she gave
+10
+A
+11 him a massage and then she asked me if I wanted to do it and
+12 then I did it or whatever and then after that like he kind
+13
+of scared me when I went there so I just decided not to go
+14
+back.
+15
+16
+Q
+Okay. The first time you went with Haley, did you
+17
+18
+go upstairs with him?
+A No, I stayed down in the kitchen.
+Okay. Did Haley tell you that -- what was
+19
+20
+entailed as to what had to be done?
+A Well she said the first time you go it's just like
+21
+22
+a massage and she said like well, the more you go supposedly
+the more he like expects and starts flirting with girls and
+23
+24.
+25
+that's what kind of like scared me.
+l Okay. I've interviewed other girls and they've
+told me pretty much the same thing about the massage but
+
+
+Case 9:08-cv-80119-KAM Document 319-3 Entered on FLSD Docket 09/22/2009 Page 4 of 8
+Page 4
+1
+there's more to that. More to the massage. Okay? That's
+2 why I didn't want mom to be in here. And you can talk to me
+3 about anything. Okay? Like I said, I've interviewed other
+4
+people already who have told me what transpired in that
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+room. I know it's going to be difficult for you but...
+A Well, the first time I went there I did a massage
+and he was just asking me a lot of questions. He seemed
+like really nice. And then he kept like staring at me and
+stuff. And then like I did a massage and he just kept
+looking at me and he was like , you're being shy and I'm
+like yeah. And he's like do you feel uncomfortable and I
+was like yeah, a little bit. And he's like okay. And he
+said well do you want to stop, and I was like no, it's okay.
+And he was like why are you like being shy and I was like
+, I don't know. And then he would like change the subject
+and he started talking about other things. And then when we
+were done he said that if like I wanted to come back and do
+more then he would like pay me more and then I would have to
+talk to Haley and I could come back.
+& Okay. What kind of questions did he ask you as
+you were massaging him?
+A
+He was asking about -- it was a year ago. I don't
+remember everything but...
+• Right.
+A He was just asking me if I had any friends that
+
+
+Case 9:08-cv-80119-KAM Document 319-3 Entered on FLSD Docket 09/22/2009 Page 5 of 8
+Page 5
+might want to give a massage and I said I don't know. Then
+he asked me about what I wanted to do when I grew up and
+stuff like that and I asked him what he did and he said he
+was like a scientist basically.
+Q
+Okay. Did he ever ask you how old you were?
+A
+No.
+No. Did he know that you were 17?
+No, I don't think so.
+Well it would have been 16 if it was a year ago,
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+23
+24
+25|
+right?
+A
+Well it like was almost a year ago.
+(Inaudible)
+17.
+Okay. During the massage did you -- were you
+naked or --
+No. I had my clothes on.
+You had all your clothes on?
+A
+Uh-huh.
+Okay. Did he touch you in any way?
+A He was like kind of like leaning towards it but I
+was like you could tell I was shy so I think that's why he
+didn't try. But I heard about other girls that he -- that
+22 he got flirtatious with them and he made them take off their
+clothes and stuff.
+Okay. What -- that was the first time you went,
+right?
+
+
+Case 9:08-cv-80119-KAM Document 319-3 Entered on FLSD Docket 09/22/2009 Page 6 of 8
+Page 6
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A
+Yeah.
+Q
+Okay.
+A
+Well, no. It was the second time that I gave him
+massage.
+The first time I went up with Haley.
+Okay. You went upstairs with Haley?
+A
+No, I was in the kitchen.
+• You were in the kitchen. That was -- you only had
+two times that you went there?
+Yeah.
+The first time you didn't do anything but just sit
+in the kitchen?
+A
+Yeah.
+Who did you sit in the kitchen with?
+A He had a l
+that was there and he had -- there
+was like two other girls there that live with him.
+Okay. Did you massage his back? Was he naked
+when you were massaging him?
+Well, he had like a towel around his -- his upper
+was (inaudible) but he had like a towel around him.
+Okay. Did he ever remove that towel?
+A
+No.
+when you were massaging him he never removed the
+towel?
+A
+U
+No.
+Okay. Did you -- did he have you touch his
+
+
+Case 9:08-cv-80119-KAM Document 319-3 Entered on FLSD Docket 09/22/2009 Page 7 of 8
+Page
+7
+1
+private area?
+2
+A No. No. I wouldn't do that.
+3
+Q
+You wouldn't do that?
+4
+Okay. Did he touch you in your private area?
+5
+A
+No. No.
+6
+Q
+No.
+7
+A
+He kept like staring at me and like, I don't know,
+8
+I just felt uncomfortable and I left. But I heard other
+9 stories that like --
+10
+11
+12
+l Right. I'm concerned with you. I know about
+other stories and I've interviewed other people have told me
+different things. That's why I'm trying to find out what
+happened to you. Okay?
+13
+14
+15
+A Uh-huh.
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+l You're the victim in this so that's why I'm trying
+to find out what happens to you.
+A
+Uh-huh.
+Okay? Who took you upstairs to the room?
+A
+This girl Sarah that lives with him.
+Q
+Okay. So Sarah took you up?
+A
+Yes.
+& Did she tell you anything? Did she say anything?
+A Huh-huh. There's a massage table and she just
+laid a towel down and she said that Jeffrey will be out for
+his massage.
+
+
+Care 9:08-cv-80119-KAM Document 319-3 Entered on FLSD Docket 09/22/2009 Page 8 of 8
+Page 8
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Okay.
+Have you received any massage training?
+A
+No.
+No.
+I have to ask.
+was Sarah one of the two girls that was in the
+kitchen with you?
+A
+Yes.
+Q
+Okay. Did you ever go back to his house?
+A
+Well, I just went there twice.
+Right.
+After that --
+After that you've never come back? Never went
+back?
+A
+A
+How much did you receive for the massage?
+Iwo hundred.
+You received 200.
+Okay. Did Haley explain to you what was going to
+be involved?
+A
+She said the first time you go there you pretty
+much just give a massage, but the more you go there like the
+more he expects. And that's it. That scared me.
+& That's what scared you?
+BY DETECTIVE DAWSON:
+• Did she say (inaudible) or did she (inaudible --
+A Say didn't have to say it exactly but she implied
+like, you know, like taking your clothes off and stuff like

vision-fixhub/court-01/01225f76c24db412c8b6f1e180f0c266530ec6b7cdef32befa8c7c9653376ef0.receipt.json

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vision-fixhub/court-01/0129dfd59d79b043225678955f1bff45128c185a3c077f1fe05c47be5c37f580.md

@@ -0,0 +1,81 @@
+Case 9:08-cv-80736-KAM Document 205-5 Entered on FLSD Docket 07/05/2013 Page 1 of 4
+Appendix E
+
+
+Case 9:08-cv-80736-KAM Document 205-5 Entered on FLSD Docket 07/05/2013 Page 2 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES,
+Respondent.
+MOTION TO SEAL
+The United States of America, by and through the undersigned Assistant United States
+Attorney, hereby moves to seal its Reply in Support of Its Motion to Dismiss for Lack of Subject
+Matter Jurisdiction for the following reasons:
+1.
+The Motion contains information regarding proceedings before West Palm Beach
+Federal Grand Jury 05-02 and West Palm Beach Federal Grand Jury 07-103, which is subject to the
+secrecy protections of Fed. R. Crim. P. 6.
+Pursuant to Rule 6(e)(6), "[r]ecords, orders, and subpoenas relating to grand-jury
+proceedings must be kept under seal to the extent and as long as necessary to prevent the
+unauthorized disclosure of a matter occurring before a grand jury."
+On November 7, 2011, the United States moved for permission to disclose limited
+information from those grand jury proceedings relevant to this litigation. The Court issued an Order
+allowing such limited disclosure, but required that all pleadings containing such information be filed
+under seal.
+
+
+Case 9:08-cv-80736-KAM Document 205-5 Entered on FLSD Docket 07/05/2013 Page 3 of 4
+WHEREFORE, the United States respectfully requests that its Reply in Support of Its
+Motion to Dismiss for Lack of Subject Matter Jurisdiction be sealed.
+DATED: January 26, 2012
+Respectfully submitted,
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+By:
+Assistant U.S. Attorney
+Florida Bar No. 0018255
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail:
+.c.villafana@usdoj.gov
+Attorney for Respondent
+CERTIFICATE OF SERVICE
+The undersigned hereby certifies and affirms that a copy of the foregoing was served via
+United States Mail this 26th day of January, 2012, upon Counsel for Petitioners Jane Doe #1 and
+Jane Doe #2.
+Wellere
+ASSISTANT U.S. ATTORNEY
+
+
+Case 9:08-cv-80736-KAM Document 205-5 Entered on FLSD Docket 07/05/2013 Page 4 of 4
+SERVICE LIST
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/
+United States District Court, Southern District of Florida
+Jaffe
+, Esq.
+Weissing
+Fistos
+Lehrman
+425 N Andrews Ave Ste 2
+Fort Lauderdale, FL 33301-3268
+brad@pathtojustice.com
+954-524-2820
+Fax: 954-524-2822
+[Service via U.S. Mail]
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+[Service via U.S. Mail]
+Attorneys for Jane Doe # 1 and Jane Doe #

vision-fixhub/court-01/0129dfd59d79b043225678955f1bff45128c185a3c077f1fe05c47be5c37f580.receipt.json

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+}

vision-fixhub/court-01/013706281b47b760735982750235e6f8eeb7193d9a7a18975ec73995c929b37b.md

@@ -0,0 +1,113 @@
+Case 9:08-cv-80381-KAM Document 79 Entered on FLSD Docket 04/29/2009 Page 1 of 5
+JANE DOE NO. 2,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80380-MARRAJ_
+JANE DOE NO. 5,
+CASE NO.: 08-CV-80381-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+- 1-
+
+
+Case 9:08-cv-80381-KAM Document 79 Entered on FLSD Docket 04/29/2009 Page 2 of 5
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA/JOHNSON
+JANE DOE NO. 7,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- 80993-CIV-MARRA/
+PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME
+TO FILE RESPONSE TO MOTIONS TO COMPEL PLAINTIFF
+TO RESPOND TO DEFENDANT'S FIRST REQUEST TO
+PRODUCE AND FIRST SET OF INTERROGATORIES, ET AL.
+Plaintiffs, by and through undersigned counsel, file this Motion for Enlargement to Time to
+File Responses to Motions to Compel Plaintiffs to Respond to Defendant's First Request to Produce
+and First Set of Interrogatories, et al., pursuant to S.D. Fla.L.R. 7.1 and Fed.R.Civ.P. 6(b), and states
+as follows:
+On April 2, 2009, Defendant Epstein filed two Motions to Compel in each of the
+above-captioned cases: (1) Motion to Compel Plaintiff to Respond to Defendant's First Request to
+Produce and to Overrule Objections, and for an Award of Defendant's Reasonable Expenses; and (2)
+Motion to Compel Plaintiff to Answer Defendant's First Set of Interrogatories, and to Overrule
+Objections, and for an Award of Defendant's Reasonable Expenses. Plaintiffs' responses to these
+- 2-
+
+
+Case 9:08-cv-80381-KAM Document 79 Entered on FLSD Docket 04/29/2009 Page 3 of 5
+Motions are due on April 29, 2009.
+2.
+Plaintiffs move for an enlargement of time to prepare and file their response to the
+Motions because of demands on Plaintiffs' counsel in this case and in other cases and matters. This
+includes an appellate brief presently due on May 1, 2009, in Doe v. School Bd. of Broward County
+and Scavella, case no. 09-10394-E, Eleventh Circuit Court of Appeals; and post-judgment motions
+and briefs in Elk v. United States, case no. 05-186L, Court of Federal Claims.
+3.
+Plaintiffs request an enlargement of time until May 6, 2009.
+4.
+Pursuant to S.D.Fla.L.R. 7.1(A), Plaintiffs' counsel has conferred with counsel for
+Defendant regarding the relief sought in this Motion, who has advised Plaintiffs' counsel that
+Defendant has no objection to the enlargement of time requested.
+WHEREFORE, Plaintiffs respectfully request an enlargement of time to file their response to
+the Motions to Compel et al., until and including May 6, 2009.
+Dated: April 29, 2009
+Respectfully submitted,
+By:
+s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+- 3-
+
+
+Case 9:08-cv-80381-KAM Document 79 Entered on FLSD Docket 04/29/2009 Page 4 of 5
+CERTIFICATE OF SERVICE
+I hereby certify that on April 29, 2009, I electronically filed the foregoing document with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day to all parties on the attached Service List in the manner specified, either via transmission of
+Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
+parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Stuart S. Mermelstein
+- 4-
+
+
+Case 9:08-cv-80381-KAM Document 79 Entered on FLSD Docket 04/29/2009 Page 5 of 5
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+igoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Is/ Stuart S. Mermelstein
+- 5-

vision-fixhub/court-01/013706281b47b760735982750235e6f8eeb7193d9a7a18975ec73995c929b37b.receipt.json

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vision-fixhub/court-01/017051fec2bb239f57192bca4a44b069d523d0d6dc2da2be2448eee06d9f03d5.md

@@ -0,0 +1,317 @@
+Entered on FLSD Docket 06/04/2009 Page 1 of 11
+-UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-
+MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-
+MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+CASE NO.: 08-CV-80380-
+MARRAJ
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+CASE NO.: 08-CV-80381-
+MARRA/
+
+
+Entered on FLSD Docket 06/04/2009 Page 2 of 11
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-
+MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-
+MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.: 08-CV-80811-MARRA/
+vS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Entered on FLSD Docket 06/04/2009 Page 3 of 11
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. II,
+Plaintiff,
+CASE NO.: 08-CV-80469-
+MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-
+MARRA_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+CASE NO.: 09-CV-80656-
+MARRA
+
+
+Document 136
+Entered on FLSD Docket 06/04/2009 Page 4 of 11
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFES JANE DOE NO. 101 AND JANE DOE NO. 102's
+REPLY TO DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO PLAINTIFFS
+JANE DOE NO. 101 AND JANE DOE NO. 102'S MOTION FOR A NO-
+CONTACT ORDER
+Plaintiffs, JANE DOE No. 101 and JANE DOE No. 102 (together, the
+"Plaintiffs"), by and through undersigned counsel, hereby reply to Defendant Jeffrey
+Epstein's Response to Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for a
+No-Contact Order (" Response") as follows:
+Plaintiffs have not, and will not, engage in any name-calling. For
+purposes of Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-
+Contact Order ("Motion"), it does not matter whether "many of the alleged victims ...
+were or are admitted prostitutes, dancers at strip clubs... or have criminal records or
+warrants for their arrests ...," Def.'s Resp. 4, or whether they were living in a monastery
+or planning on becoming nuns, lawyers, or judges. This matter is quite simple: The
+allegations are that, when these victims were minors, Defendant sexually exploited,
+abused, molested, and/or battered them. Regardless of the victims' character or
+Defendant's character, it is obvious that Defendant, Jeffrey Epstein, a 55-year-old
+designated sexual offender and convicted felon, should have no contact with his victims.
+2.
+Defendant makes much ado that one victim allegedly telephoned Jack
+Goldberger's office to complain that Mr. Goldberger was holding up the matter. Def.'s
+
+
+Case 9:08-cv-80119-KAM Document 136 Entered on FLSD Docket 06/04/2009 Page 5 of 11
+Resp. 5. We have no reason to doubt the truth of that statement by defense counsel.
+Unsurprisingly, a 21-year-old homeless, ill, and desperate victim who had waited for
+settlement funds for seven weeks regretfully may have called Mr. Goldberger's office;
+but whether she did so has nothing to do with Plaintiffs' Motion. Likewise, if Defendant
+attempts to telephone undersigned counsel to complain or have any other contact with
+undersigned counsel, undersigned counsel will handle the matter as professionally as Jack
+Goldberger did by refusing to speak to the opposing party.
+The troublesome part of Defendant's position is his counsel's statement in
+the attached correspondence that, pursuant to Rule 4-4.2 of the Rules of Professional
+Conduct, "parties to a matter may communicate directly with each other ...." In this
+case, Plaintiffs' counsel are concerned that Defendant or his agents may assert that
+alleged right, and we vehemently disagree that they should have that prerogative in these
+Plaintiffs' cases. No legal justification exists for Defendant or his agents to have any
+direct communications with victims whom Defendant, Jeffrey Epstein, sexually
+exploited, abused, molested, and/or battered.
+In his Response, see Def.'s Resp. 4, and in his letter, counsel for Defendant,
+Jeffrey Epstein, professes that "it is not Mr. Epstein's intention to have any direct contact
+with [our] clients." This statement poses two significant problems. First, it leaves the
+door open for Defendant's investigator(s) or other agents) to contact the victims. Such
+contact would not be direct and would not be inconsistent with his professed intention to
+refrain from direct contact with his victims. See, e.g.,
+v. All State Home Mortgage,
+Inc., No. 08-3564, 2009 WL 1391527, at *1 (6th Cir. May 15, 2009) (intimidation of
+plaintiffs-loan officers with contentious relationship with defendant-mortgage company
+
+
+Case 9:08-cv-80119-KAM Document 136 Entered on FLSD Docket 06/04/2009 Page 6 of 11
+through threatening phone calls by defendant's employees considered indirect contact in
+violation of no-contact order in civil suit claiming violation of Fair Labor Standards Act);
+Commonwealth v.
+661 N.E. 2d 666, 666-67 (Mass. App. Ct. 1996) (defendant's
+anonymous delivery of flowers to victim considered indirect contact in violation of nocontact order). Second, Defendant's counsel does not state that Defendant will not have
+any contact with his victims. He merely states Defendant's intentions. Unfortunately,
+the last five months is replete with other incidents in which Defendant, through his
+counsel, has stated his intentions and thereafter changed his mind. Defendant, Jeffrey
+Epstein, feels free—-and actually is free-
+-to change his mind and his stated intentions.
+His victims deserve more than that. Because they are traumatized and fearful, they
+require for their security a firm, unambiguous commitment that Defendant will not
+directly or indirectly contact either of them; considering the situation, any secure
+commitment is attainable only via a Court order. Plaintiffs cannot emotionally afford to
+be in a position in which Defendant can unilaterally change his mind.
+4.
+In the event that Defendant wants to be present at the deposition of a
+Plaintiff or at a Court hearing where a Plaintiff is to attend, the Court can easily resolve
+such situations at that time. Meanwhile, the sole purpose of Defendant's refusal to agree
+to not contact these Plaintiffs is to leave them intimidated and in fear of being in the
+presence of the man who has sexually exploited, abused, molested, and/or battered them.
+One would think that, instead, Defendant would have voluntarily agreed with Plaintiffs'
+prior request to have no contact directly or indirectly, including through his agents, and
+would want to demonstrate to the Court that he will not contact his victims; his refusal to
+stay away from them is nothing short of disturbing.
+
+
+Document 136 Entered on FLSD Docket 06/04/2009 Page 7 of 11
+Although not requested, if Defendant's counsel seeks some type of
+reciprocity, Plaintiffs' counsel would agree in writing, and would not oppose a Court
+order prohibiting Plaintiffs from contacting Defendant, Jeffrey Epstein. It is obvious to
+undersigned counsel that there should be absolutely no contact between the parties to
+these lawsuits.
+WHEREFORE, Plaintiffs request this Court to enter an Order prohibiting
+Defendant, Jeffrey Epstein, and/or his agents from directly or indirectly contacting them.
+Dated: June 4, 2009.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No.
+101 and Jane Doe No. 102
+By:
+s/ Robert C. Josefsberg
+Robert C. Josefsberg
+Fla. Bar No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Ste. 80(
+Miami, FL 3313(
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Document 136 Entered on FLSD Docket 06/04/2009 Page 8 of 11
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that, on this 4th day of June, 2009, we electronically
+filed the foregoing document with the Clerk of the Court using CM/ECF. We also certify
+that the foregoing document is being served this day on all counsel of record identified on
+the attached Service List either via transmission of Notices of Electronic Filing generated
+by CM/ECF or in some other authorized manner for those counsel or parties who are not
+authorized to receive electronically Notices of Electronic Filing.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+ttorneys for Plaintiffs Jane Doe N
+01 and Jane Doe No. 10
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Bar No. 040856
+osefsberg@podhurst.co
+atherine W. Ezc
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Ste. 800
+
+
+Entered on FLSD Docket 06/04/2009 Page 9 of 11
+SERVICE LIST
+JANE DOE NO. 2 v. JEFFREY EPSTEIN
+Case No. 08-CV-80119-MARRA/
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone: (561) 842-2820
+Fax: (561) 515-3148
+rcrit@bclclaw.com
+mpike@bclclaw.com
+Counsel for Defendant, Jeffrey Epstein
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant, Jeffrey Epstein
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+ecf@brucereinhartlaw.com
+Counsel for Co-Defendant,
+Jack Scarola, Esq.
+Jack P.
+, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9456
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff C.M.A.
+
+
+Case 9:08-cv-80119-KAM Document 136 Entered on FLSD Docket 06/04/2009 Page 10 of 11
+Adam Horowitz, Esq.
+Stuart Mermelstein, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Blvd., Suite 2218
+Miami, FL 33160
+Phone: (305) 931-2200
+Fax: (305) 931-0877
+ahorowitz@sexabuscattorney.com
+smermelstein@sexabuseattorney.com
+Counsel for Plaintiffs in Related Case Nos. 08-80069, 08-80119,08-80232, 08-80380, 08-
+80381, 08-80993, 08-80994
+Spencer Todd Kuvin, Esq.
+Theodore Jon Leopold, Esq.
+Leopold Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Phone: (561) 515-1400
+Fax: (561) 515-1401
+skuvin@leopoldkuvin.com
+tleopold@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No. 08-08804
+Richard Willits, Esq.
+Richard H. Willits, P.A
+2290 10" Ave North, Suite 404
+Lake Worth, FL 33461
+Phone: (561) 582-7600
+Fax: (561) 588-8819
+lawyerwillits@aol.com
+reelrhw@hotmail.com
+Counsel for Plaintiff in Related Case No. 08-80811
+Brad
+Esq.
+Law Office of Brad
+& Associates, LIC
+2028
+Street, Suite 202
+Hollywood, FL 33020
+Phone: (954) 414-8033
+Fax: (954) 924-1530
+bedwards@rra-law.com
+be@bradedwardslaw.com
+Counsel for Plaintiff in Related Case No. 08-80893
+Isidro Manuel
+„Esq-
+Elkins & Boehringer
+
+
+Case 9:08-cv-80119-KAM Document 136 Entered on FLSD Docket 06/04/2009 Page 11 of 11
+224 Datura Avenue, Suite 900
+West Palm Beach, FL 33401
+Phone: (561) 832-8033
+Fax: (561) 832-7137
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-80469

vision-fixhub/court-01/017051fec2bb239f57192bca4a44b069d523d0d6dc2da2be2448eee06d9f03d5.receipt.json

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vision-fixhub/court-01/01f891e7b5c8f29f8619e2cf741bd95525cb0afddeb2f1c1d2df4ea36da0bb5f.md

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+Case 1:19-cv-11869-MKV-DCF
+EP
+Document 9 Filed 01/10/20 Page 1 of 1
+Florida Office
+*O+
+Seth M. Lehrman *+
+Brittany N.
+Matthew D. Weissing **
+*0
+POTTINGER LLC
+425 North Andrews Avenue
+Suite 2
+Fort Lauderdale, FL. 33301
+Telephone (954)524-2820
+Fax (954)524-2822
+New York Office
+J. Stanley Pottinger ‡
+† Admitted in Califomia
+• Admitted in District of Columbia
+* Admitted in Florida
+‡ Admitted in New York
+* Board Certified Civil Trial Lawyer
+January 10, 2020
+FILED VIA ECE
+Magistrate Judge Debra C. Freeman
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl St., New York, NY 10007
+Re:
+VE v. Nine East 7ls/Street et al., No. 19-cv-07625 (S.D.N.Y.) (Nathan, J.)
+Katlyn Doe v. Darren K. Indyke et al., No. 19-cv-07771 (S.D.N.Y.) (Castel, J.)
+Pricilla Doe v. Darren K. Indyke et al.., No. 19-cv-07772 (S.D.N.Y.) (Carter, J.)
+Lisa Doe v. Darren K. Indyke et al., No. 19-cv-07773 (S.D.N.Y.) (Ramos, J.)
+Anastasia Doe v. Darren K. Indyke, et al., No. 19-cv-11869 (S.D.N.Y.) (Nathan, J.)
+Dear Judge Freeman:
+We represent the five Plaintiffs referenced above whose cases have all been assigned to Your Honor. While
+we agree with Defendants' assertion that our discussions with the designers and administrator of the Epstein
+Victims' Compensation Program have been positive and productive, in our view, it remains important to
+every aspect of the process that our cases are not stayed and that they proceed accordingly.
+As we explained during the Case Management Conference that was held on November 21, 2019, our clients
+have varying views of the process, and while each will maintain an open mind about potential alternative
+resolution, those who have filed lawsuits do not wish to delay the expeditious litigation of their claims.
+plan by February 6, 2020.
+Respectfully Submitted,
+die
+425 North Andrews Avenue, Suite 2, Fort Lauderdale, Florida 33301
+954.524.2820 office
+954.524.2822 fax

vision-fixhub/court-01/01f891e7b5c8f29f8619e2cf741bd95525cb0afddeb2f1c1d2df4ea36da0bb5f.receipt.json

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vision-fixhub/court-01/020dca423f7cbd4341adbe3c3d37cf0ae4326d3c973d829961f8c25c350acf73.md

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+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 1 of 15
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRAJ
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRAJT
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 2 of 15
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA/
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80811 -MARRA/
+JANE DOE,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRA/
+DOE II,
+VS.
+CASE NO.: 08-CV- 80469-MARRA/
+Plaintiff,
+2
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 3 of 15
+JEFFREY EPSTEIN et al.,
+Defendant.
+JANE DOE NO. 101,
+CASE NO.: 08- CV-80591-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+CASE NO.: 08- CV-80656-MARRA
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFES JANE DOES 2-7'S RESPONSE TO DEFENDANT'S MOTION TO
+COMPEL AND/OR IDENTIFY PLAINTIFFS IN THE STYLE OF THIS CASE AND
+MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY SUBPOENAS FOR
+PURPOSES OF DISCOVERY, OR ALTERNATIVELY, MOTION TO DISMISS
+"SUA SPONTE", WITH INCORPORATED MEMORANDUM OF LAW
+Plaintiffs, JANE DOES 2-7, hereby serve their Response to Defendant's Motion to
+Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane Doe in
+Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss "Sua
+Sponte", With Incorporated Memorandum of Law, and state as follows:
+The lawsuits filed by JANE DOES 2-7 involve private, intimate facts pertaining
+to their own childhood sexual abuse and exploitation by Defendant Jeffrey Epstein.
+3
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 4 of 15
+2.
+Jane Does 2-7 filed their suits under a pseudonym' to prevent public disclosure of
+the private, highly sensitive and intimate facts pertaining to their sexual assaults, and the public
+association of their identities with Defendant Epstein and these assaults.
+Dr. Gilbert Kliman," a well-known forensic psychiatrist with an expertise in the
+field of child trauma, has met with and evaluated each of Jane Does 2-7 and opined that public
+disclosure of their real names would create a substantial risk to them of further psychological
+harm. See Exhibit "A", Declaration of Gilbert Kliman, M.D.
+Dr. Kliman opines as follows:
+Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis
+of posttraumatic stress disorder trauma. In effect, release of their identity and
+public intrusion into their personal life represents a reenactment of the shame of
+sexual traumatization. Repetition and reenactment are central pathologies that
+afflict sexual trauma survivors.
+Victims of sexual abuse often rely upon some form of dissociation, splitting or
+denial, as a defensive means to manage overwhelming affects associated with the
+sexual trauma. Each of the plaintiff girls has employed some variation of this
+defense, both during the massages and then subsequently following disclosure of
+the abuse. Primitive, maladaptive responses of this nature will become
+additionally reinforced as a result of public disclosure.
+Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR,
+is that the trauma was associated with human design factors (such as cruel
+intention to do harm, rape, torture). Trauma of this origin has a tendency to
+produce more "severe or long lasting" posttraumatic stress disorder than natural
+events (DSM IV TR p. 464). À policy of deliberate revelation of the names of the
+victims would reinforce the sense of design, pattern and policy of human
+intentions.
+It is my opinion, with a reasonably high degree of medical certainty that the
+defense motion to allow public disclosure of the plaintiffs' identity is clinically
+" Defendant and his counsel are aware of the real names of Jane Does 2-7.
+" A copy of the curriculum vitae of Dr. Gilbert Kliman is attached hereto as Exhibit "B".
+4
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 5 of 15
+and ethically a wrongful plan. The act of revealing their identity against their
+wishes places the plaintiffs at risk, in the best of circumstances, of suffering an
+aggravation of existing diagnostic concerns. It is more probable than not that
+releasing personal identities will
+an exacerbation and magnification of
+symptoms lending to increased risk of revictimization and retraumatization.
+See Exhibit "A", 99l 13-15, 21
+5.
+Given the private nature of the allegations in this lawsuit and the serious risk of
+harm to the mental health of Jane Does 2-7 if a public disclosure of their identities were required,
+Jane Does 2-7 should be permitted to continue using a pseudonym in this lawsuit.
+6.
+Notably, in one of the cases consolidated for purposes of discovery, Jane Doe v.
+Jeffrey Epstein, Case No. 08-80893, this Court recognized the harm likely to result from public
+disclosure of the victims' identities in these cases, and allowed the Plaintiff in that case to
+"proceed in this action under the pseudonym Jane Doe'", by Order dated October 6, 2008.
+Jeffrey Epstein sets forth no facts to support his bare contention that Jane Does 2-
+7 use of a pseudonym in these proceedings interferes with his "constitutional due process right."
+See Motion to Compel, p. 3. Defendant and his counsel know the identities of these Plaintiffs.
+8.
+Defendant also requests the Court's permission to use the real names of Jane Does
+2-7 in various third-party subpoenas for discovery purposes. Defendant does not identify any of
+the entities or persons to whom he intends to send subpoenas. An order granting the relief
+requested without limitations would essentially nullify Jane Does 2-7's right to proceed
+anonymously. Jane Does 2-7 therefore object to the issuance of third-party subpoenas, and
+submit that Defendant can obtain the discovery he seeks by alternative means that will preserve
+the confidentiality of the Jane Does 2-7's identities.
+9.
+If this Court were to permit third party subpoenas or records custodian
+depositions using the existing captions and identifying Jane Does 2-7 in the body of the
+5
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 6 of 15
+subpoena by their names, due to publicity surrounding the Defendant's crimes, then Jane Does 2-
+7 would effectively be revealed as abuse victims in these cases against Defendant Epstein. Any
+subpoenas or notices to third parties therefore should not disclose the type of action or the
+Defendant's identity. There are alternatives which would preserve Jane Does 2-7's anonymity
+and be more efficient and cost-effective at the same time. For instance, Defendant can obtain
+records from various non-party sources through Plaintiffs' counsel, who can certify that they
+have obtained the records through authorizations signed by Jane Does 2-7. Another means to
+obtain non-party records concerning Plaintiffs is the appointment of a special
+who would
+verify authenticity and completeness of the records.
+10.
+Finally, Jeffrey Epstein's request that this Court order a "sua sponte" dismissal is
+illogical. Sua sponte means "[w]ithout prompting or suggestion; on its own motion." Black's
+Law Dictionary 1437 (7th ed.1999). Thus, the definition of sua sponte does not fit these
+circumstances, because the Court is being prompted by Epstein's Motion. Velchez v. Carnival
+Corp, 331 F.3d 1207 (11th Cir. 2003). In any event, there is no basis or authority to support a
+dismissal of these cases.
+WHEREFORE, Plaintiffs Jane Does 2-7 respectfully request that (i) this Court deny
+Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to
+Identify Jane Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion
+to Dismiss "Sua Sponte", in its entirety; (ii) Plaintiffs Jane Does 2-7 be permitted to continue
+using their pseudonyms in this litigation; (ill) this Court order that records from non-parties
+relating to Jane Does 2-7, including medical and employment records, only be obtained through
+Plaintiffs' counsel by means of signed authorizations that do not include the caption or identify
+Epstein as the party seeking records, or alternatively, appoint a special
+to obtain the
+6
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 7 of 15
+records, who would verify authenticity and completeness of the records; and (iv) all other relief
+this Court deems just and appropriate.
+MEMORANDUM OF LAW
+PLAINTIFFS JANE DOES 2-7 SHOULD BE PERMITTED
+TO PROCEED ANONYMOUSLY IN THIS CASE DUE TO THE
+SENSITIVE, PRIVATE NATURE OF THE UNDERLYING FACTS
+AND THE RISK OF PSYCHOLOGICAL HARM TO THE PLAINTIFFS
+Federal courts permit a party to proceed under a pseudonym when special circumstances
+warrant anonymity. See, e.g., Roe v. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 685-87
+(11th Cir.2001); Does / thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1068-69 (9th
+Cir.2000); James v. Jacobson, 6 F.3d 233, 238-39 (4th Cir. 1993); EW v. New York Blood Center,
+213 F.R.D. 108, 110-12 (E.D.N.Y.2003); Javier v.
+-Botello, 211 F.R.D. 194, 196
+(W.D.N.Y.2002); Doe v. |
+105 F.Supp.2d 40, 43-44 (E.D.N.Y.1999); Doe v. United Servs.
+Life Ins. Co., 123 F.R.D. 437, 439 (S.D.N.Y.1988). Sexual assault victims are a paradigmatic
+example of those entitled to a grant of anonymity. See Doe No. 2 v. Kolko, 242 F.R.D. 193 (E.D.
+N.Y. 2006); Doe v. Blue Cross & Blue Shield United of Wisc., 112 F.3d 869, 872 (7th Cir.1997)
+("fictitious names are allowed when necessary to protect the privacy of ... rape victims, and other
+particularly vulnerable parties or witnesses"); see also Doe v. City of Chicago, 360 F.3d 667, 669
+(7th Cir. 2004).
+The decision whether to allow a plaintiff to proceed anonymously is within the court's
+discretion. See Aware Woman Ctr., 253 F.3d at 684; Javier, 211 F.R.D. at 195; EW, 213 F.R.D.
+at 110. As set forth above, this Court exercised its direction in one of the consolidated cases,
+Jane Doe v. Jeffrey Epstein, Case No. 08-80893, to allow a plaintiff to proceed under the
+pseudonym "Jane Doe" in an Order dated October 6, 2008.
+7
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 8 of 15
+Courts will permit a party to proceed under a pseudonym where "the party's need for
+anonymity outweighs prejudice to the opposing party and the public's interest in knowing the
+party's identity." Does I Thru XXIII, 214 F.3d at 1068; see Javier, 211 F.R.D. at 195; EW, 213
+F.R.D. at I11; As set forth herein, the balancing test in this case weighs in favor of permitted
+plaintiff to continue to proceed anonymously:
+In undertaking this balance, courts have considered such facts as
+(1) whether the plaintiff is suing the government or a private
+person; (2) whether the plaintiff would be compelled to disclose
+intimate information; (3) whether plaintiff would be compelled to
+under a pseudonym would thereby be prejudiced; (6) the ages of
+the parties whose identity is to be suppressed; (7) the extent to
+which the identity of the litigant has been kept confidential; (8)
+whether, because of the purely legal nature of the issues presented
+or otherwise, there is an atypically weak public interest in knowing
+the litigants' identities; and (9) the public interest in guaranteeing
+open access to proceedings without denying litigants access to the
+justice system.
+Doe v. Del Rio, 241 F.R.D. 154, 157 (S.D. N.Y. 2006)
+The public has a strong interest in protecting the identities of sexual assault victims so
+that other victims will not be deterred from reporting such crimes. See Doe v.
+, 202 F.R.D.
+173, 176 (E.D.Pa.2001) (granting anonymity to sexual assault victim); Doe No. 2 v. Kolko, 242
+F.R.D. 193 (E.D. N.Y. 2006). That is particularly true in these consolidated cases where there
+are numerous victims with similar claims. Although these cases have gained considerable media
+attention, there appears to be little public interest in knowing the specific identity of each of the
+victims.
+With regard to the second factor, courts have granted anonymity to protect against
+disclosure of a wide range of issues involving matters of the utmost intimacy, including sexual
+8
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 9 of 15
+assault. See, e.g., Aware Woman Cir., 253 F.3d at 685 (abortion); EW, 213 F.R.D. at 111
+(infection with hepatitis B); Doe v. L
+•. 202 F.R.D. 173, 176 (E.D.Pa.2001) (sexual assault
+victim); [
+105 F.Supp.2d at 42 (sexual assault victim); WGA v. Priority Pharmacy, Inc., 184
+F.R.D. 616, 617 (E.D.Mo.1999) (status as AIDS patient); Doe v. United Servs. Life Ins. Co., 123
+F.R.D. 437, 439 (S.D.N.Y.1988) (sexual orientation); see also Blue Cross, 112 F.3d at 872
+(recognizing rape victims as entitled to anonymity). It cannot be reasonably denied that a
+person's sexual history - especially during their childhood - is an intimate fact. When the
+childhood sexual history includes criminal sexual contact by an adult, the facts are even more
+intimate and personal. In the electronic age in which we live, these concerns are heightened. As
+federal courts have recognized in this context, it is now possible to "determine whether a given
+individual is a party to a lawsuit in federal court anywhere in the country by the simplest of
+computer searches, to access the docket sheet of any such case electronically, and ... that entire
+case files will be accessible over the Internet." Doe v. City of New York, 201 F.R.D. 100, 102
+(S.D.N.Y.2001) (denying anonymity where any injury was purely reputational and case did not
+involve private or intimate matter); see EW, 213 F.R.D. at 112-13.
+As Dr. Kliman explains in his Declaration, disclosure of Jane Does 2-7's identities will
+place these Plaintiffs "at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media and
+general public. This type of exposure humiliates many victims and represents another betrayal of
+trust. Public exposure places the plaintiff's at further risk of stigmatization, shame and
+retraumatization." See Exhibit "A" at 9l 3. Dr. Kliman also finds it of no consequence that some
+of the plaintiffs are now legally adults in that "[dJue to traumatization the plaintiffs are arrested
+in their development, and even those who are now legally adult are arrested in part to adolescent
+9
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 10 of 15
+aspects of psychology." Id. at 9 4
+The policy of protecting victims of sexual misconduct from undue embarrassment and
+disclosure of their private affairs is firmly established in Fed.R.Evid. 412. The protections of
+Rule 412 are designed to "encourage victims of sexual misconduct to institute and participate in
+legal proceedings against alleged offenders." (Committee Notes to 1994 Amendment).
+Likewise, many states in this country, including Florida and New York, have similarly enacted
+laws to protect the anonymity of sexual assault victims. See Fla. Stat. $$794.024, 794.026
+(2008); N.Y. Civil Rights Law § 50-b (McKinney 2009). In 1994, the Florida Legislature passed
+The Crime Victims Protections Act. The legislative stated purpose for the Act was "to protect
+the identity of victims of sexual crimes." Fla. AGO, 2003-56, 2003 WL 22971082 (Dec. 15,
+2003). Under §794.024, Florida Statutes, court records that identify the name and/or address of a
+victim of a sexual crime are presumed to be confidential and exempt from public access. Id.
+Similarly, upon approving New York's rape shield law, then Governor Mario
+stated,
+"sexual assault victims have unfortunately had to endure a terrible invasion of their physical
+privacy. They have a right to expect that this violation will not be compounded by a further
+invasion of their privacy." 1991 McKinney's Sessions Laws of N.Y., at 2211-2212 (quoted in
+Deborah S. v. Diorio, 153 Misc.2d 708, 583 N.Y.S.2d 872 (N.Y.City Civ. Ct.1992)); see also
+Coker v. Georgia, 433 U.S. 584, 597, 97 S.Ct. 2861, 53 L.Ed.2d 982 (1977) ("Short of homicide,
+[rape] is the ultimate violation of self").
+As to the fourth factor of risk injury, Dr. Kliman has evaluated Jane Does 2-7, and has
+concluded that the childhood sexual abuse at issue has caused features of post-traumatic stress
+disorder (PTSD), including shame, guilt, helplessness, and powerlessness. See Exhibit "A" at TYl
+4-7. Dr. Kliman further states,
+"it is more probable than not that releasing personal identities
+10
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 11 of 15
+will
+an exacerbation and magnification of symptoms lending to increased risk of
+revictimization and retraumatization." Id. at 9| 21. Thus, this is not a case analogous to those
+cited by defendant in which the plaintiffs were merely at risk of "personal embarrassment."
+Instead, there is a genuine and immediate risk of psychological harm.
+None of the cases cited by Defendant where courts denied a plaintiff's request for
+anonymity involved victims of childhood sexual assault or evidence of emotional or
+psychological harm that would result from disclosure of the plaintiff's identity. See Doe v. Hartz,
+52 F.Supp.2d 1027 (N.D.Iowa 1999); Doe v. Shakur, 164 F.R.D. 359 (E.D.N.Y.1996); Doe v.
+Bell Atlantic Bus. Sys. Servs., 162 F.R.D. 418 (D.Mass.1995); Doe v. Univ. of Rhode Island, 28
+Fed.R.Serv.3d 366, 1993 WL 667341 (D.R.I. Dec. 28, 1993).
+As to the factor of prejudice, the Defendant does not identify how his ability to conduct
+discovery or impeach Jane Does 2-7's credibility has been or will be impaired if these Plaintiffs
+are permitted to proceed under a pseudonym. See EW, 213 F.R.D. at 112,
+105 F.Supp.2d
+at 44-45. Other than the need to make redactions and take measures not to disclose these
+Plaintiffs' identities, Defendant will not be hampered or inconvenienced merely by Plaintiffs'
+anonymity in court papers. As set forth above, Defendant already knows their true identities. See
+Aware Woman Center, 253 F.3d at 687 (no prejudice where plaintiff offered to disclose her name
+to defendant); EW, 213 F.R.D. at 112;
+105 F.Supp.2d at 44-45.
+Il.
+DEFENDANT SHOULD NOT BE PERMITTED TO USE
+THE REAL NAMES OF JANE DOES 2-7 IN THIRD-PARTY
+SUBPEONAS EXCEPT FOR THOSE ISSUED TO PERSONS WHOM
+PLAINTIFES HAVE ALREADY DISCLOSED THEIR SEXUAL ABUSE
+As for the use of Jane Does 2-7's real names in subpoenas issued to non-parties, a party
+may obtain discovery of any non-privileged matter that is relevant to a claim or defense of any
+party. Fed.R.Civ.P. 26(b)(I). However, a district court may limit discovery "for good cause
+11
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 12 of 15
+shown" by making "any order which justice requires to protect a party or person from
+annoyance, embarrassment, oppression, or undue burden or expense," including that the
+discovery not be had or that it be had only by a method other than that selected by the party
+seeking discovery. Fed.R.Civ.P. 26(c). Jane Does 2-7 have articulated a specific and substantial
+harm from disclosure of their identities.
+If this Court were to permit Defendant to issue third-party subpoenas containing Jane
+Doe 2-7's real names, the identity of the Defendant, and/or facts pertaining to the nature of the
+case to whomever Defendant wants, it would be akin to requiring these Plaintiffs to use their real
+name in the pleadings.
+Instead, Jane Does 2-7 propose to voluntarily execute authorizations
+(which would not contain the case names or the identity of the Defendant) to allow Defendant to
+obtain education, employment, and medical records to be used for purposes of this litigation
+only. Alternatively, Defendant can obtain the records through a special
+who would
+verify authenticity and completeness of the records. Either of these approaches would not only
+place Jane Does 2-7 at less risk of psychological harm, but would also be more cost-effective and
+efficient.
+CONCLUSION
+Based on the foregoing, Plaintiffs Jane Does 2-7 respectfully request that Defendant's
+Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane
+Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss
+"Sua Sponte" be denied in its entirety, and that Plaintiffs Jane Does 2-7 be permitted to continue
+using their pseudonyms in this litigation. Additionally, to avoid public disclosure of the
+Plaintiff's identities in non-party records discovery, Plaintiffs Jane Does 2-7 request that such
+3 Defendant and Plaintiff have previously agreed that education records can be obtained in this
+12
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 13 of 15
+discovery be obtained either through Plaintiffs' counsel by means of written authorizations, or by
+the appointment of a special
+Dated: June 8, 2009
+Respectfully submitted,
+By:
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs Jane Doe Nos. 2-7
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+manner in lieu of subpoenas.
+13
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 14 of 15
+CERTIFICATE OF SERVICE
+I hereby certify that on June 8, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+14
+
+
+Case 9:09-cv-80469-KAM Document 34 Entered on FLSD Docket 06/08/2009 Page 15 of 15
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+/s/ Adam D. Horowitz
+15

vision-fixhub/court-01/020dca423f7cbd4341adbe3c3d37cf0ae4326d3c973d829961f8c25c350acf73.receipt.json

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vision-fixhub/court-01/021fb995b735819a05063a05c23264761644b8bfbedb3e2cc8b24403f2b0d4f1.md

@@ -0,0 +1,39 @@
+Case 9:08-CV-80119-KAM Document 305-10
+Entered on FLSD Docket 09/17/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-,
+JANE DOE NO. 2,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+ORDER ON DEFENDANT'S, JEFFREY EPSTEIN, MOTION FOR SANCTIONS
+AND TO COMPEL DEPOSITION OF JANE DOE NO. 4
+AND MEMORANDUM IN SUPPORT THEREOF
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion For
+Sanctions and to Compel Deposition of Jane Doe No. 4. Having considered Defendant's motion,
+it is HEREBY ORDERED and ADJUDGED that:
+Defendant's motion is hereby GRANTED: Plaintiff shall pay sanctions in the amount of
+in costs and S
+in fees directly to Burman, Critton, Luttier and
+Coleman within 10 days, and further directs that the Plaintiff make herself available for
+deposition no later than October
+_ 2009 beginning at 9:30 a.m. at the same location. Mr.
+Epstein shall not be present in the building on the day of the deposition absent a court order on
+pending motions.
+
+
+Case 9:08-cv-80119-KAM Document 305-10 Entered on FLSD Docket 09/17/2009 Page 2 of 2
+Jane Doe No. 4 v. Epstein
+Page 2
+DONE and ORDERED this
+_ day of
+, 2009.
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies:
+Counsel of Record

vision-fixhub/court-01/021fb995b735819a05063a05c23264761644b8bfbedb3e2cc8b24403f2b0d4f1.receipt.json

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+{
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+}

vision-fixhub/court-01/02207df99afa4071cdde255c21cd373f88b8218018530a5f228b9ee6bf61077c.md

@@ -0,0 +1,66 @@
+Case 1:20-cv-00484-JGK-DCF Document 19-2 Filed 02/07/20 Page 1 of 3
+DOBAR
+• •
+СОЛІТ ОГ АРУЕТА
+On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals,
+the District of Columbia Bar does hereby certify that
+Kevin RBoyle
+was duly qualified and admitted on June 4, 1999 as an attorney and counselor entitled to
+practice before this Court; and is, on the date indicated below, an Active member in good
+standing of this Bar.
+In Testimony Whereof,
+I have hereunto subscribed my
+name and affixed the seal of this
+Court at the City of
+Washington, D.C., on January
+16, 2020.
+Gulis a Entelle
+JULIO A. CASTILLO
+Clerk of the Court
+Issued By:
+District of Columbia Bar Membership
+For questions or concerns, please contact the D.C. Bar Membership Office at 202-626-3475 or email
+memberservices@dcbar.org.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 19-2 Filed 02/07/20 Page 2 of 3
+The State Bar
+of California
+180 Howard Street, San Francisco, CA 94105
+888-800-3400
+OFFICE OF ATTORNEY REGULATION
+& CONSUMER RESOURCES
+AttorneyRegulation@calbar.ca.gov
+CERTIFICATE OF STANDING
+January 11, 2020
+TO WHOM IT MAY CONCERN:
+This is to certify that according to the records of the State Bar, KEVIN RICHARD
+BOYLE, #192718 was admitted to the practice of law in this state by the Supreme
+Court of California on December 11, 1997 and has been since that date, and is at
+date hereof, an ACTIVE licensee of the State Bar of California; and that no
+recommendation for discipline for professional or other misconduct has ever been
+made by the Board of Trustees or a Disciplinary Board to the Supreme Court of the
+State of California.
+THE STATE BAR OF CALIFORNIA
+Dina DiLoreto
+Custodian of Records
+
+
+Case 1:20-cv-00484-JGK-DCF Document 19-2 Filed 02/07/20 Page 3 of 3
+Supreme Gourt of California
+JORGE E. NAVARRETE
+Clerk and Executice Officer of the Supreme Court
+CERTIFICATE OF THE CLERK OF THE SUPREME COURT
+OF THE
+STATE OF CALIFORNIA
+KEVIN RICHARD BOYLE
+1, JORGE E. NAVARRETE, Clerk/Executive Officer of the Supreme Court of the State of
+California, do hereby certify that KEVIN RICHARD BOYLE, #192718, was on the 11th
+day of December 1997, duly admitted to practice as an attorney and counselor at law in
+all the courts of this state, and is now listed on the Roll of Attorneys as a member of the
+bar of this state in good standing.
+Witness my hand and the seal of the court
+on the 28th day of January 2020.
+JORGE E. NAVARRETE
+Clerk/Executive Officer of the Supreme Court
+M. Alfaro, Deputy CR

vision-fixhub/court-01/02207df99afa4071cdde255c21cd373f88b8218018530a5f228b9ee6bf61077c.receipt.json

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