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+### IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE No. 101,
+
+Plaintiff,
+
+VS.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+09-80591
+
+Civil Action No.
+
+CH-MARRA
+
+MAGISuper
+
+COMPLAINT AND DEMAND FOR JURY TRIAL
+
+FILED by i th - S - D C INTAKE
+
+APR 1 7 2009
+
+STEVEN M LARIMORE CLERK U.S DIST. CT. \$.0 OF FLA. MIAMI
+
+# COMPLAINT AND DEMAND FOR JURY TRIAL
+
+Plaintiff, Jane Doe No. 101 ("Jane Doe"), brings this Complaint against Defendant, Jeffrey Epstein, and states as follows:
+
+## PARTIES. JURISDICTION, AND VENUE
+
+- I. At all times material to this cause of action, Plaintiff, Jane Doe, was a resident of Palm Beach County, Florida.
+- 2. This Complaint is brought under a fictitious name to protect the identity of Plaintiff, Jane Doe, because this Complaint makes sensitive allegations of sexual assault and abuse of a then minor.
+- 3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
+- 4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is currently incarcerated in the Palm Beach County Stockade.
+- 5. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953.
+
+6. This Court has jurisdiction of this action and the claims set forth herein pursuant to 18 U.S.C. § 2255.
+
+7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(a), as a substantial part of the events giving rise to the claim occurred in this District.
+
+# STATEMENT OF FACTS
+
+8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male, approximately 50 years old. Epstein is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a Boeing 727. Until his incarceration, he maintained his principal place of residence in the largest home in Manhattan. a 51,000-square-foot eight-story mansion on the Upper East Side. Upon information and belief, he also owns a \$6.8 million mansion in Palm Beach, Florida, a \$30 million 7,500-acre ranch in New Mexico he named "Zorro," and a 70-acre private island known as Little St. James in St. , U.S. Virgin Islands. The allegations herein concern Defendant's conduct while at his lavish estate in Palm Beach.
+
+9. Upon information and belief, Defendant has a sexual preference for underage minor girls. He engaged in a plan, scheme, or enterprise in which he gained access in his home to countless relatively economically disadvantaged minor girls, sexually assaulted or molested these girls, and then gave them money.
+
+10. Beginning in or around 2001 through in or around September 2007, Defendant used his resources and his influence over vulnerable minor children to engage in a systematic pattern of sexually exploitative behavior.
+
+11. Defendant's plan and scheme reflected a particular pattern and method. Defendant coerced and enticed impressionable, vulnerable, and relatively economically less
+
+fortunate minors to participate in various acts of sexual misconduct that he committed upon them. Defendant's scheme involved the use of underage girls as well as other individuals to recruit other underage girls. Upon information and belief, Defendant or an authorized agent would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach residence. His assistants would seek out economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered generally \$200 to \$300 per "massage" session—and who Defendant and/or his assistants perceived as less likely to complain to authorities or have credibility issues if allegations of improper conduct were made. The then minor Plaintiff and other minor girls, some as young as 14 years old, were transported to Defendant's Palm Beach county mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with "massages."
+
+12. Defendant would pay the procurer of each girl's "appointment" approximately \$200. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated with the assistance, support, and facilitation of at least three assistants who helped him orchestrate this child exploitation enterprise. These assistants would often arrange times for underage girls to come to Defendant's residence, transport or cause the transportation of underage girls to Defendant's residence, escort the underage girls to the massage room where Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the conclusion of each "massage appointment," and, upon information and belief, take nude photographs and/or videos of the underage girls' for Defendant without their knowledge.
+
+13. Epstein designed the scheme to secure a private place in Defendant's mansion where only persons employed and invited by Epstein would be present, so as to reduce the chance of detection of Defendant's sexual abuse and prostitution as well as to make it more difficult for the minor girls to flee the premises and/or to credibly report his actions to law enforcement or other authorities. The girls were usually transported by his employees, agents, and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to flee his mansion.
+
+14. Upon arrival at Defendant's mansion, each underage victim would generally be introduced to one of Defendant's assistants, who would gather the girl's personal contact information. The minor girl would then be led up a flight of stairs to a room that contained a massage table and a large shower. The staircase leading to the room was plastered with nude photographs of young girls, including some photographs depicting two or more young girls engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such photographs in each of his four homes and on his computer.
+
+15. At times, if it was the girl's first "massage" appointment, another female would be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant would start his massage wearing only a small towel, which eventually would be removed. Defendant would direct the girl to massage him, giving her specific instructions as to where and how he wanted to be touched, and then direct her to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including masturbation, fondling the minor's breasts and/or sexual organs, touching the minor's vagina with a vibrator and/or back massager, digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex, and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution. The exact degree of molestation and frequency with which the sexual crimes took place varied and is not yet completely known; however, at least when Defendant was in Palm Beach, Florida, such acts occurred usually on a daily basis and, in most instances, several times a day.
+
+16. As previously stated in paragraph 14, Defendant displayed nude photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and belief, some of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate commerce.
+
+17. Consistent with the foregoing plan and scheme, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff. Plaintiff, Jane Doe, was recruited by one of Defendant's agents to give Defendant a massage for compensation. Plaintiff was apprehensive, but needed the money and finally agreed to go. Plaintiff was first brought to Defendant's mansion in or about the spring of 2003, when she was merely 17 years old and in high school. Epstein's procurer drove her to Jeffrey Epstein's mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a shower and a massage table, where she was left alone. A woman with dark hair, an accent, and naked from the waist up entered and tried to coax Plaintiff to remove her shirt, but Plaintiff refused. Atter the woman showed Plaintiff how to use the lotions that were there, the woman left. Defendant walked in wearing only a small towel. He lay down on the massage table still wearing the small towel, and Plaintiff began to massage his shoulders and neck. Nervously, she asked him what he did for a living. Defendant responded that he was a scientist. Defendant asked Plaintiff what year she would graduate high school, to which Plaintiff honestly replied that she would graduate in 2004. Plaintiff massaged Defendant's lower back and calves. Defendant
+
+told her to remove his towel. Defendant told her that he had just worked out and wanted his buttocks massaged. Although disgusted, she was afraid to refuse and did it. At some point, Defendant ordered Plaintiff to remove her clothes. In shock, fear, and trepidation, Plaintiff partly complied, removing only her shirt and bra. When Defendant turned over, Plaintiff was afraid and embarrassed and she wanted to leave. Defendant repeatedly told her to relax and complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to him. He began masturbating and then began fondling her breasts. He asked her to do more and mentioned more money, which she adamantly declined. Defendant continued masturbating until he ejaculated. Plaintiff next recalls that she received \$200 and was transported by the procurer, whom she later learned received \$200 for having brought her to Epstein's mansion.
+
+IR. Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer made another appointment for her to return, but Plaintiff didn't want to sec Defendant. By having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon each instance of contact and/or abuse.
+
+19. In addition to the direct sexual abuse and molestation of the then minor Plaintiff, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff to bring him another minor girl in a promised exchange for money. Rather than go herself, Plaintiff and the procurer took another girl there one time.
+
+20. As a result of these encounters with Defendant, Plaintiff, Jane Doe, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
+
+other damages associated with Defendant's controlling and manipulating her into a perverse and unhealthy way of life.
+
+21. Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by her telling him her high school graduation year, as well as his own actions, and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiff's age of minority. In fact, his preference for underage girls was well-known to those who regularly procured them for him.
+
+22. Defendant, Jeffrey Epstein, committed the above-referenced acts upon the then minor Plaintiff in violation of federal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, transport of child pornography, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(b), § 2423(c), § 2251, § 2252, § 2252A(a)(1), § 2252A(g)(1), and § 1591.
+
+23. After investigations by the Palm Beach Police Department, the Palm Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in June 2008 in the Fifteenth Judicial Circuit in Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe. Plaintiff hereby exclusively seeks civil remedies pursuant to 18 U.S.C. § 2255.
+
+## COUNT ONE (Cause of Action for Coercion and Enticement of Minor to 1 I-maze in Prostitution or Sexual Activity pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C. S 2422(b)1
+
+24. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.
+
+25. Defendant, Jeffrey Epstein, used a facility or means of interstate commerce to knowingly persuade, induce, or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b).
+
+26. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+27. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+## COUNT TWO (Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant to 18 U.S.C. 5 2255 in Violation of 18 U.S.C. 5 2423(b))
+
+28. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.
+
+29. Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(0, with minor females, in violation of 18 U.S.C. § 2423(b).
+
+30. Plaintiff. Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+31. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+## COUNT THREE (Cause of Action for Sex Trafficking of Children pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 1591(a))
+
+32. Plaintiff, Jane Doe, hereby adopts, repeats. realleges, and incorporates by reference the allegations contained in paragraphs I through 23 above.
+
+33. Defendant, Jeffrey Epstein, knowingly, in or affecting interstate or foreign commerce, recruited. enticed, and obtained Plaintiff, Jane Doe, knowing that she had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(cX1), in violation of 18 U.S.C. § 1591(a)(1).
+
+34. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+35. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and
+
+unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+## COUNT FOUR (Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 22511
+
+36. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.
+
+37. Defendant, Jeffrey Epstein, knowingly induced, enticed, or coerced then minor Plaintiff Jane Doe to engage in sexually explicit conduct for the purpose of producing a visual depiction of such conduct in violation of 18 U.S.C. § 2251. As previously stated in paragraphs 14 and 16, Defendant displayed a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate commerce.
+
+38. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+39. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+## COUNT FIVE (Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit Conduct pursuant to 18 U.S.C. 2255 in Violation of 18 U.S.C. \$ 2252(a)(1)1
+
+40. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.
+
+41. Defendant, Jeffrey Epstein. knowingly mailed, transported, or shipped in interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252(1). As previously stated in paragraphs 14, 16, and 37, upon information and belief, Defendant displayed a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate commerce.
+
+42. As previously stated in paragraph 21, any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiff's age of minority. In fact, his preference for underage girls was well-known to those who regularly procured them for him.
+
+43. Plaintiff, Janc Doc, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+44. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+## COUNT SIX (Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C. 4 2252A(a)(1))
+
+45. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.
+
+46. Defendant, Jeffrey Epstein, knowingly mailed, transported, or shipped in interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1).
+
+47. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+48. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe.
+
+49. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+## COUNT SEVEN (Cause of Action for Emitting in a Child Exploitation Enterprise pursuant to 18 U.S.C. 2255 in Violation of 18 U.S.C. 4 2252A(211
+
+50. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.
+
+51. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A(g)(1). As more fully set forth above in paragraphs 9 through 19, Defendant's actions involved countless victims and countless incidents of abuse, and he committed those offenses against minors in concert with at least three other persons.
+
+52. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+53. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of ha privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+Date: April 17, 2009 Rob..4 6 WE
+
+Robert C. Joset 473:111o. 4 0408 56
+
+Katherine W. Ezell, Bar No. 114771
+
+
+25 West Flagler Street, Suite 800
+
+Miami, Florida 33130
+
+(305) 358-2800
+
+(305) 358-2382 (fax)
+
+riosefsbenfectodhurst.com
+
+kezell@podhurst.com
+
+Attorneys for Plaintiff
+
+# DEMAND FOR JURY TRIAL
+
+Plaintiff demands to have her case tried before a jury.
+
+Robert C. Josefs Bar No. 04\326
+
+Katherine W. Ezell, Bar No. 114771
+
+
+25 West Flagler Street, Suite 800
+
+Miami, Florida 33130
+
+(305) 358-2800
+
+(305) 358-2382 (fax)
+
+riosefsbergOnodhurst.com
+
+kezell@podhurst.com
+
+Attorneys for Plaintiff
+
+C • kon
+
+The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) **NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.**
+
+**I. (a) PLAINTIFFS**
+
+Jane Doe No. 101
+
+(b) County of Residence of First Listed Plaintiff West Palm Beach  
+(EXCEPT IN U.S. PLAINTIFF CASES)
+
+(c) Attorney's (Firm Name, Address, and Telephone Number)
+
+Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq.  
+25 W. Flagler St., Suite 800  
+Miami FL 33130
+
+(d) Check County Where Action Arose:  MIAMI-DADE  MONROE  BROWARD  PALM BEACH  ST. LUCIE  INDIAN RIVER  OKEECHOBEE HIGHLANDS
+
+**II. BASIS OF JURISDICTION**
+
+ 1 U.S. Government Plaintiff  3 Federal Question (U.S. Government Not a Party)  
+ 2 U.S. Government Defendant  4 Diversity (Indicate Citizenship of Parties in Item III)
+
+**III. CITIZENSHIP OF PRINCIPAL PARTIES**
+
+(For Diversity Cases Only)  1 PTF  2 PTF  3 PTF  4 PTF  5 PTF  6 PTF  7 PTF  8 PTF  9 PTF  10 PTF  11 PTF  12 PTF  13 PTF  14 PTF  15 PTF  16 PTF  17 PTF  18 PTF  19 PTF  20 PTF  21 PTF  22 PTF  23 PTF  24 PTF  25 PTF  26 PTF  27 PTF  28 PTF  29 PTF  30 PTF  31 PTF  32 PTF  33 PTF  34 PTF  35 PTF  36 PTF  37 PTF  38 PTF  39 PTF  40 PTF  41 PTF  42 PTF  43 PTF  44 PTF  45 PTF  46 PTF  47 PTF  48 PTF  49 PTF  50 PTF  51 PTF  52 PTF  53 PTF  54 PTF  55 PTF  56 PTF  57 PTF  58 PTF  59 PTF  60 PTF  61 PTF  62 PTF  63 PTF  64 PTF  65 PTF  66 PTF  67 PTF  68 PTF  69 PTF  70 PTF  71 PTF  72 PTF  73 PTF  74 PTF  75 PTF  76 PTF  77 PTF  78 PTF  79 PTF  80 PTF  81 PTF  82 PTF  83 PTF  84 PTF  85 PTF  86 PTF  87 PTF  88 PTF  89 PTF  90 PTF  91 PTF  92 PTF  93 PTF  94 PTF  95 PTF  96 PTF  97 PTF  98 PTF  99 PTF  100 PTF  101 PTF  102 PTF  103 PTF  104 PTF  105 PTF  106 PTF  107 PTF  108 PTF  109 PTF  110 PTF  111 PTF  112 PTF  113 PTF  114 PTF  115 PTF  116 PTF  117 PTF  118 PTF  119 PTF  120 PTF  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272 PTF  273 PTF  274 PTF  275 PTF  276 PTF  277 PTF  278 PTF  279 PTF  280 PTF  281 PTF  282 PTF  283 PTF  284 PTF  285 PTF  286 PTF  287 PTF  288 PTF  289 PTF  290 PTF  291 PTF  292 PTF  293 PTF  294 PTF  295 PTF  296 PTF  297 PTF  298 PTF  299 PTF  300 PTF  301 PTF  302 PTF  303 PTF  304 PTF  305 PTF  306 PTF  307 PTF  308 PTF  309 PTF  310 PTF  311 PTF  312 PTF  313 PTF  314 PTF  315 PTF  316 PTF  317 PTF  318 PTF  319 PTF  320 PTF  321 PTF  322 PTF  323 PTF  324 PTF  325 PTF  326 PTF  327 PTF  328 PTF  329 PTF  330 PTF  331 PTF  332 PTF  333 PTF  334 PTF  335 PTF  336 PTF  337 PTF  338 PTF  339 PTF  340 PTF  341 PTF  342 PTF  343 PTF  344 PTF  345 PTF  346 PTF  347 PTF  348 PTF  349 PTF  350 PTF  351 PTF  352 PTF  353 PTF  354 PTF  355 PTF  356 PTF  357 PTF  358 PTF  359 PTF  360 PTF  361 PTF  362 PTF  363 PTF  364 PTF  365 PTF  366 PTF  367 PTF  368 PTF  369 PTF  370 PTF  371 PTF  372 PTF  373 PTF  374 PTF  375 PTF  376 PTF  377 PTF  378 PTF  379 PTF  380 PTF  381 PTF  382 PTF  383 PTF  384 PTF  385 PTF  386 PTF  387 PTF  388 PTF  389 PTF  390 PTF  391 PTF  392 PTF  393 PTF  394 PTF  395 PTF  396 PTF  397 PTF  398 PTF  399 PTF  400 PTF  401 PTF  402 PTF  403 PTF  404 PTF  405 PTF  406 PTF  407 PTF  408 PTF  409 PTF  410 PTF  410 PTF  411 PTF  412 PTF  413 PTF  414 PTF  415 PTF  416 PTF  417 PTF  418 PTF  419 PTF  420 PTF  421 PTF  422 PTF  423 PTF  424 PTF  425 PTF  426 PTF  427 PTF  428 PTF  429 PTF  430 PTF  431 PTF  432 PTF  433 PTF  434 PTF  435 PTF  436 PTF  437 PTF  438 PTF  439 PTF  440 PTF  441 PTF  442 PTF  443 PTF  444 PTF  445 PTF  446 PTF  447 PTF  448 PTF  449 PTF  450 PTF  451 PTF  452 PTF  453 PTF  454 PTF  455 PTF  456 PTF  457 PTF  458 PTF  459 PTF  460 PTF  461 PTF  462 PTF  463 PTF  464 PTF  465 PTF  466 PTF  467 PTF  468 PTF  469 PTF  470 PTF  471 PTF  472 PTF  473 PTF  474 PTF  475 PTF  476 PTF  477 PTF  478 PTF  479 PTF  480 PTF  481 PTF  482 PTF  483 PTF  484 PTF  485 PTF  486 PTF  487 PTF  488 PTF  489 PTF  490 PTF  491 PTF  492 PTF  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604 PTF  605 PTF  606 PTF  607 PTF  608 PTF  609 PTF  610 PTF  611 PTF  612 PTF  613 PTF  614 PTF  615 PTF  616 PTF  617 PTF  618 PTF  619 PTF  620 PTF  621 PTF  622 PTF  623 PTF  624 PTF  625 PTF  626 PTF  627 PTF  628 PTF  629 PTF  630 PTF  630 PTF  631 PTF  632 PTF  633 PTF  634 PTF  635 PTF  636 PTF  637 PTF  638 PTF  639 PTF  640 PTF  641 PTF  642 PTF  643 PTF  644 PTF  645 PTF  646 PTF  647 PTF  648 PTF  649 PTF  650 PTF  651 PTF  652 PTF  653 PTF  654 PTF  655 PTF  656 PTF  657 PTF  658 PTF  659 PTF  660 PTF  661 PTF  662 PTF  663 PTF  664 PTF  665 PTF  666 PTF  668 PTF  669 PTF  670 PTF  671 PTF  672 PTF  673 PTF  674 PTF  675 PTF  676 PTF  677 PTF  678 PTF  679 PTF  680 PTF  681 PTF  682 PTF  683 PTF  684 PTF  685 PTF  686 PTF  687 PTF  688 PTF  689 PTF  690 PTF  691 PTF  692 PTF  693 PTF  694 PTF  695 PTF  696 PTF  697 PTF  698 PTF  699 PTF  700 PTF  701 PTF  702 PTF  703 PTF 
+
+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION
+
+## ATTACHMENT TO CIVIL COVER SHEET
+
+FOR: Jane Doe No. 101 v. Jeffrey Epstein
+
+# VI. RELATED/RE-FILED CASE(S):
+
+08-80069
+
+08-80119
+
+08-80232
+
+08-80380
+
+08-80381
+
+08-08804
+
+08-80811
+
+08-80893
+
+08-80993
+
+08-80994
+
+08-80469

marker2-fixhub/court-doe-101-v-epstein/EFTA02738115/EFTA02738115.receipt.json

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738134/EFTA02738134.md

@@ -0,0 +1,41 @@
+## UNITED STATES DISTRICT COURT
+
+Southern District of Florida
+
+Case Number:
+
+v.
+
+JANE DOE 101,
+
+JMETEEX EPSTEIN,
+
+Plaintiff
+
+Defendant
+
+09-80591
+
+NV-MARRA MAGIOUDGE
+
+## SUMMONS IN A CIVIL CASE
+
+TO: (Name and address of defendant)
+
+Jeffrey Epstein, Palm Beach Bounty Stockade, West Palm Beach, FL and/Or by serving his counsel: David W. Spicer, Esq., 11000 Prosperity Faros Rd, Suite 104, Palm Beach Gardens, FL 33410 or Jack A. Goldberger, Esq., 250 S. Australizn Ave., Suite 1400, West Palm Beach, FL 33401, or Robert D. Critton, Jr., Esq , 515 N. Flagler Drive, Suite 400, West Palm Beach, FL 33401
+
+YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEY (name and address)
+
+Robert C. Josef &erg, Esq/Katherine W. Ezell, Esq.
+
+PCOHURSP ORSECK, P.A. 25 W. Flagler St., Suite 800 Miami, FL 33130
+
+an answer to the complaint which is herewith se td ed upon you, within days after service of this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the complaint You must also file your answer with the Clerk of this Court within a reasonable period of time after service.
+
+Steven M. Larimore
+
+CT nIC OF COURT DATE
+
+APR 17 nog
+
+(BY) DEPUTY CLERK

marker2-fixhub/court-doe-101-v-epstein/EFTA02738134/EFTA02738134.receipt.json

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738135/EFTA02738135.md

@@ -0,0 +1,41 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 09-8059I-CIV-MARRA
+
+JANE DO NO. 101,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendants.
+
+## ORDER REQUIRING COUNSEL TO CONFER, FILE JOINT SCHEDULING REPORT AND FILE JOINT DISCOVERY REPORT
+
+THIS ORDER has been entered upon the filing of the complaint. Plaintiff's counsel is hereby ORDERED to forward to all defendants, upon receipt of either an answer or a motion pursuant to Fed. R. Civ. P. 12(b), a copy of this order.
+
+It is further ORDERED:
+
+- I. Every motion when filed shall be accompanied by a proposed order, except that motions to dismiss and motions for summary judgment need not be accompanied by a proposed order.
+- 2. Pretrial discovery in this case shall be conducted in accord with Local Rule 16.1 and Rule 26 of the Federal Rules of Civil Procedure.
+- 3. Pursuant to Rule 26(f) of the Federal Rules of Civil Procedure, unless this action is excluded under Rule 26(aX I )(E), the parties must confer within twenty-one (21) days after the last responding party either files an answer or a motion pursuant to Fed. R. Civ. P. 12(b), whichever is earlier, to consider the nature and basis of their claims and defenses and the possibilities for a prompt settlement or resolution of the case, to make or arrange for the disclosures required by Rule 26(a)( I), and to develop a proposed discovery plan that indicates the
+
+parties' views and proposals concerning the matters listed in Rule 26(t).
+
+4. The parties are jointly responsible for submitting a written report of this conference outlining the proposed discovery plan within 14 days after the conference.
+
+5. Counsel for the parties shall hold a scheduling conference either at the same time as the discovery conference described in Rule 26(t) or within fourteen (14) calendar days thereafter. See Local Rule 16.1(B).
+
+6. Within fourteen (14) days of the scheduling conference, counsel shall file a joint scheduling report pursuant to Local Rule 16.1(B)(2). This report shall indicate the proposed month and year for the trial plus the estimated number of trial days required, as well as an indication of whether the trial is to be a jury trial or bench trial.
+
+7. The parties may submit a single report combining the discovery plan report and the scheduling conference report.
+
+8. Failure of counsel or unrepresented parties to file a discovery plan report or joint scheduling report may result in dismissal, default, and the imposition of other sanctions including attorney's fees and costs.
+
+DONE AND SIGNED in at West Palm Beach, Palm Beach County, Florida, this 20th day of April, 2009.
+
+> KENNETH A. MARRA United States District Judge
+
+Copies furnished to:
+
+All counsel

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738137/EFTA02738137.md

@@ -0,0 +1,91 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/
+
+
+
+
+
+JANE DOE NO. 3,
+
+
+
+
+
+JANE DOE NO. 4,
+
+
+vs. JEFFREY EPSTEIN,
+
+
+JANE DOE NO. 5,
+
+
+
+
+CASE NO.: 013-CV-80232-MARRA
+
+CASE NO.: 08-CV-80380-MARRA,
+
+CASE NO.: 08-CV-80381-MARRA/
+
+
+JANE DOE NO. 6,
+
+
+
+
+
+CASE NO.: 08-80994-CIV-MARRA/M.
+
+JANE DOE NO. 7, CASE NO.: 08-80993-CIV-MARRA
+
+
+
+
+
+C.M.A., CASE NO.: 08-8081 I -CIV-MARRA
+
+
+
+
+
+JANE DOE, CASE NO.: 08- 80893-CIV-MARRA/
+
+
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+DOE II, CASE NO.: 09- 80469-CIV-MARRA/M.
+
+
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+JANE DOE NO. 101, CASE NO.: 09- 80591-CTV-MARRa
+
+
+
+
+
+## ORDER
+
+THIS CAUSE is before the Court on Plaintiffs' Motion for Protective Order Against Piecemeal Depositions of Jane Doe No.'s 2, 3, 4, and 7 and Motion to Consolidate Cases for Purposes of Discovery (DE 66 in 08-80119; DE 58 in 08-80232; DE 73 in 08-80380; DE 23 in 08-80993). The Court has reviewed the motions, responses, replies, and is otherwise fully advised in the premesis. It is hereby
+
+ORDERED AND ADJUDGED as follows:
+
+Plaintiffs' Motion for Protective Order Against Piecemeal Depositions is GRANTED, pursuant to Fed. R. Civ. P. 26(c). As to each of the ten above-styled cases, Defendant is limited to a single deposition of each Plaintiff, during which Defendant may depose the plaintiff as both a party and a witness to all other cases of a similar nature of which the plaintiff deposed is aware. Defendant should not expect to be able to re-depose any plaintiff relative to any new cases that may be filed. Therefore, Defendant should examine each plaintiff about the facts relating to all individuals of whom they are aware, regardless of whether an individual has in fact filed a claim against Defendant. In the event additional cases are filed, upon a showing of good cause, the Court will determine whether Defendant will be permitted to re-depose any of the plaintiffs as witnesses to the allegations made in those newly filed cases.
+
+Plaintiffs' Motion to Consolidate Cases for Purposes of Discovery is GRANTED. In the interests of judicial economy and efficiency, cases 08-80119, 08-80232, 08-80380, and 08-80993 are hereby CONSOLIDATED for purposes of discovery only.
+
+Additionally, the parties in the other six above-styled causes (08-80381, 08-80994, 08-80811, 08-80893 09-80469, 09-80591) are hereby ORDERED TO SHOW CAUSE on or before May 5, 2009 why all of the cases should not be consolidated for discovery purposes.
+
+DONE AND ORDERED in Florida, this 28th day of April, 2009 at West Palm Beach, Palm Beach County,
+
+Copies furnished to: all counsel of record
+
+rZ KENNETH A. MARRA United States District Judge

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738141/EFTA02738141.md

@@ -0,0 +1,283 @@
+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE No. 101,
+
+Civil Action No. 9:09-cv-80591-KAM
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL
+
+## FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL
+
+Plaintiff, Jane Doe No. 101, brings this Complaint against Defendant, Jeffrey Epstein, and states as follows:
+
+# PARTIES. JURISDICTION, AND VENUE
+
+- I. At all times material to this cause of action, Plaintiff, Jane Doe No. 101, was a resident of Palm Beach County, Florida.
+- 2. This Complaint is brought under a fictitious name to protect the identity of Plaintiff, Jane Doe No. 101, because this Complaint makes sensitive allegations of sexual assault and abuse of a then minor.
+- 3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida.
+- 4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is currently incarcerated in the Palm Beach County Stockade.
+- 5. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953.
+
+6. This Court has jurisdiction of this action and the claims set forth herein pursuant to 18 U.S.C. § 2255.
+
+7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(6), as a substantial part of the events giving rise to the claim occurred in this District.
+
+# STATEMENT OF FACTS
+
+8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male, approximately 50 years old. Epstein is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, and influence. He owns a fleet of aircraft that includes a Gulfstream IV. a helicopter, and a Boeing 727, as well as a fleet of motor vehicles. Until his incarceration, he maintained his principal place of residence in the largest home in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East Side. Upon information and belief, he also owns a \$6.8 million mansion in Palm Beach, Florida, a \$30 million 7,500-acre ranch in New Mexico he named "Zorro," and a 70-acre private island known as Little St. James in St. M, U.S. Virgin Islands, a mansion in London's Westminster neighborhood, and a home in the Avenue Foch area of Paris. The allegations herein concern Defendant's conduct while at his lavish homes and/or numerous other locations both nationally and internationally.
+
+9. Upon information and belief, Defendant has a sexual preference for underage minor girls. He engaged in a plan, scheme, or enterprise in which he gained access in his home to countless relatively economically disadvantaged minor girls, sexually assaulted, molested, and/or exploited these girls, and then gave them money.
+
+10. Beginning in or around 1998 through in or around September 2007, Defendant used his resources and his influence over vulnerable minor children to engage in a systematic pattern of sexually exploitative behavior.
+
+II. Defendant's plan and scheme reflected a particular pattern and method. Defendant coerced and enticed impressionable, vulnerable, and relatively economically less fortunate minors to participate in various acts of sexual misconduct that he committed upon them. Defendant's scheme involved the use of underage girls as well as other individuals to recruit other underage girls. Upon information and belief, Defendant or an authorized agent would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach residence. His assistants would seek out economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered generally \$200 to \$300 per "massage" session—and who Defendant and/or his assistants perceived as less likely to complain to authorities or have credibility issues if allegations of improper conduct were made. The then minor Plaintiff and other minor girls, some as young as 14 years old, were transported to Defendant's Palm Beach county mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with "massages."
+
+12. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated with the assistance, support, and facilitation of at least three assistants who helped him orchestrate this child exploitation enterprise. These assistants would often arrange times for underage girls to come to Defendant's residence, transport or cause the transportation of underage girls to Defendant's residence, escort the underage girls to the massage room where Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the conclusion of each "massage appointment." and, upon information and belief, take sexually explicit photographs and/or videos of the underage girls' for Defendant without their knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of dollars.
+
+13. Epstein designed the scheme to secure a private place in Defendant's mansion where only persons employed and invited by Epstein would be present, so as to reduce the chance of detection of Defendant's sexual abuse and prostitution as well as to make it more difficult for the minor girls to flee the premises and/or to credibly report his actions to law enforcement or other authorities. The girls were usually transported by his employees, agents, and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to flee his mansion.
+
+14. Upon arrival at Defendant's mansion, each underage victim would generally be introduced to one of Defendant's assistants, who would gather the girl's personal contact information. The minor girl would then be led up a flight of stairs to a room that contained a massage table and a large shower. The staircase leading to the room was plastered with photographs of nude young girls, including some photographs depicting two or more young girls engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such photographs in each of his four homes and on his computer.
+
+15. At times, if it was the girl's first "massage" appointment, another female would be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant would start his massage wearing only a small towel, which eventually would be removed. Defendant and/or the other female would direct the girl to massage him, giving the minor girl specific instructions as to where and how he wanted to be touched, and then direct her to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including masturbation, fondling the minor's breasts and/or sexual organs, touching the minor's vulva, vagina, and/or anus with a vibrator and/or back massager and/or his finger(s) and/or his penis, digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex, and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution and/or enticing the then minor girl to engage in sexual acts with another female in Defendant's presence. The exact degree of molestation and frequency with which the sexual crimes took place varied and is not yet completely known; however, at least when Defendant was in Palm Beach, Florida, such acts occurred usually on a daily basis and, in most instances, several times a day. In order to facilitate the daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency readily available.
+
+16. As previously stated in paragraph 14, Defendant displayed photographs of nude underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and belief, some of the photographs Defendant's possession of Defendant were taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement.
+
+17. Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to contact these minor girls for the purpose of coercing them into acts of prostitution and to enable himself to commit sexual battery against them and/or acts of lewdness in their presence, and he conspired with others, including assistants and/or his driver(s) and/or pilot(s), and his socialite
+
+friend/partner, Ghislaine Maxwell. w further these acts and to avoid police detection. Defendant's systematic pattern of sexually exploitative behavior referred to in paragraph 10 and described in paragraphs 11 through the present paragraph occurred at all of Defendant's domestic and international residences and/or places of lodging and/or modes of transportation.
+
+18. Consistent with the foregoing plan and scheme, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff. Plaintiff, Jane Doe No. 101, was recruited by one of Defendant's agents to give Defendant a massage for compensation. Plaintiff was apprehensive, but needed the money and finally agreed to go. Plaintiff was first brought to Defendant's mansion in or about the spring of 2003, when she was merely 17 years old and in high school. Epstein's procurer drove her to Jeffrey Epstein's mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a shower and a massage table, where she was left alone. A woman with dark hair, an accent, and naked from the waist up entered and tried to coax Plaintiff to remove her shirt, but Plaintiff refused. After the woman showed Plaintiff how to use the lotions that were there, the woman left. Defendant walked in wearing only a small towel. He lay down on the massage table still wearing the small towel, and Plaintiff began to massage his shoulders and neck. Nervously, she asked him what he did for a living. Defendant responded that he was a scientist. Defendant asked Plaintiff what year she would graduate high school, to which Plaintiff honestly replied that she would graduate in 2004. Plaintiff massaged Defendant's lower back and calves. Defendant told her to remove his towel. Defendant told her that he had just worked out and wanted his buttocks massaged. Although disgusted, she was afraid to refuse and did it. At some point, Defendant ordered Plaintiff to remove her clothes. In shock, fear, and trepidation, Plaintiff partly complied, removing only her shirt and bra. When Defendant turned over, Plaintiff was afraid and embarrassed and she wanted to leave. Defendant repeatedly told her to relax and
+
+complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to him. He began masturbating and then began fondling her breasts. He asked her to do more and mentioned more money, which she adamantly declined. Defendant continued masturbating until he ejaculated. Plaintiff next recalls that she received \$200 and was transported by the procurer, whom she later learned received \$200 for having brought her to Epstein's mansion.
+
+19. Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer made another appointment for her to return, but Plaintiff didn't want to see Defendant. By having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon each instance of contact and/or abuse.
+
+20. In addition to the direct sexual abuse and molestation of the then minor Plaintiff, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff to bring him another minor girl in a promised exchange for money. Rather than go herself, Plaintiff and the procurer took another girl there one time.
+
+21. As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 101, has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's controlling and manipulating her into a perverse and unhealthy way of life.
+
+22. Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by her telling him her high school graduation year, as well as his own actions, and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiff's age of minority. Defendant's preference for underage girls was well-known to those who regularly procured them for him.
+
+23. Defendant, Jeffrey Epstein, committed the above-referenced acts upon the then minor Plaintiff in violation of federal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, transport of child pornography, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(b), § 2423(e), § 2251, § 2252, § 2252A(a)(1), and § 2252A(gX1).
+
+24. In June 2008, after investigations by the Palm Beach Police Department, the Palm Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe No. 101. Plaintiff hereby exclusively seeks civil remedies pursuant to 18 U.S.C. § 2255.
+
+## COUNT ONE fCause of Action for Coercion and Enticement of Minor to Engage in Prostitution or Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2422(b))
+
+25. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above.
+
+26. Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign commerce to knowingly persuade, induce, entice, or coerce Jane Doe No. 101, when she was under the age of 18 years, to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b).
+
+27. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+28. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+## COUNT TWO (Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2423(b))
+
+29. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above.
+
+30. Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate and/or foreign commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, including the then minor Plaintiff, in violation of 18 U.S.C. § 2423(6).
+
+31. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+32. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature. and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+#### COUNT THREE (Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2251)
+
+33. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above.
+
+34. Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the then minor Plaintiff, Jane Doe No. 101, to engage in sexually explicit conduct for the purpose of producing a visual depiction of such conduct in violation of 18 U.S.C. § 2251. As previously stated in paragraphs 14 and 16, Defendant displayed a myriad of photographs of underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more sexually explicit photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement.
+
+35. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+36. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+## COUNT FOUR
+
+#### (Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit Conduct pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2252(a)(1))
+
+37. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above.
+
+38. Defendant, Jeffrey Epstein, upon information and belief, knowingly mailed, transported, shipped, or sent via computer and/or facsimile in or affecting interstate or foreign commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit conduct in violation of 18 U.S.C. § 2252(a)( I). As previously stated in paragraphs 14, 16, and 34, upon information and belief, Defendant displayed a myriad of nude photographs of underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more sexually explicit photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement.
+
+39. As previously stated in paragraph 22, any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse
+
+of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiff's age of minority. Defendant's preference for underage girls was well-known to those who regularly procured them for him.
+
+40. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+41. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+## COUNT FIVE (Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2252A(a)(1))
+
+42. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above.
+
+43. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via computer or facsimile in or affecting interstate and/or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1). As previously stated in paragraph 16, Defendant displayed a myriad of nude photographs of underage girls throughout his homes, including his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and nude photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement.
+
+44. As previously stated in paragraph 22, any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew
+
+and should have known of Plaintiff's age of minority. Defendant's preference for underage girls was well-known to those who regularly procured them for him.
+
+45. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+46. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+## COUNT SIX (Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. 2255 in Violation of 18 U.S.C. § 2252A(2))
+
+47. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above and Counts One through Five.
+
+48. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A(g)(1). As more fully above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 1591 (sex trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 U.S.C. §§ 2251, 2252(a)(1), and 2252(A)(a)(1)), and Chapter 117 (transportation for illegal sexual activity in violation of 18 U.S.C. §§ 2422, and 2423). As more fully set forth above in paragraphs 9 through 19, Defendant's actions involved countless victims and countless separate incidents of abuse, and he committed those offenses against minors in concert with at least three other persons.
+
+49. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+50. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+Date: May 1, 2009
+
+Robert C. Josefsberg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) rjosefsberg@podhurst.com kezell@podhurst.com
+
+Attorneys for Plaintiff
+
+# CERTIFICATE OF SERVICE
+
+WE HEREBY CERTIFY that on this day of May, 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. Attorneys for Plaintiff
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Br No. 040856 riosefsbera@vodhurst.com Katherine W. Ezell Ha. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+# DEMAND FOR JURY TRIAL
+
+Plaintiff demands to have her case tried before a jury.
+
+Robert C. Josefsberg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) rjosefsberg@podhurst.com kezell@podhurst.com
+
+Attorneys for Plaintiff
+
+## CERTIFICATE OF SERVICE
+
+WE HEREBY CERTIFY that on this day of May, 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. Attorneys for Plaintiff
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Br No. 040856 rjosefsberg@podhurst.com Katherine W. Ezell Fla. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+## SERVICE LIST
+
+JANE DOE NO. 101 v. JEFFREY EPSTEIN Case No. 08-CV-80591-MARRA I United States District Court, Southern District of Florida
+
+Robert Critton, Esq. Burman, Critton, Luther & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 rcrit@bcIdlaw.com
+
+Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 jagesq@bellsouth.net
+
+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 Co-counsel for Defendant, Jeffrey Epstein
+
+Jack Scarola, Esq. Jack P. M, 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@searcvlaw.com jph@searcylaw.com Counsel for Plaintiff C.M.A.
+
+Adam Horowitz, Esq. Stuart Mermelstein, Esq. Herman & Mermelstein 18205 Biscayne Blvd. Suite 2218 Miami, FL 33160
+
+Phone: (305) 931-2200
+
+Fax: (305) 931-0877
+
+ahorowitz@sexabuseattomev.com
+
+smermelstein@sexabuseattomev.com
+
+Counsel for Plaintiffs in Related Cases 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 10th 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, LLC
+
+2028 Street, Suite 202
+
+Hollywood, FL 33020
+
+Phone: (954) 414-8033
+
+Fax: (954) 924-1530
+
+bedwards@rra-Iaw.com
+
+be@bradedwardslaw.com
+
+Counsel for Plaintiff in Related Case No. 08-80893
+
+Isidro Manuel =, Esq.
+
+Elkins & Boehringer
+
+224 Datum 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

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738164/EFTA02738164.md

@@ -0,0 +1,174 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA
+
+
+
+
+
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA
+
+
+
+
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA
+
+
+
+
+
+JANE DOE NO. 5, CASE NO.: 08-CV-8038I-MARRA
+
+
+
+
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRA=.
+
+
+
+
+
+JANE DOE NO. 7, CASE NO.: 08-CV-80993-MARRA
+
+
+
+
+
+C.M.A., CASE NO.: 08-CV-8081I-MARRA
+
+
+
+
+
+JANE DOE, CASE NO.: 08-CV-80893-MARRA
+
+
+
+
+
+JANE DOE NO. 11, CASE NO.: 08-CV-80469-MARRA1
+
+
+
+
+
+
+JANE DOE NO. 101, CASE NO.: 08-CV-80591-MARRAi
+
+
+
+
+
+
+## PLAINTIFF JANE DOE 101'S RESPONSE TO COURT'S ORDER TO SHOW CAUSE REGARDING CONSOLIDATION FOR DISCOVERY
+
+Plaintiff JANE DOE 101, by and through her undersigned counsel, responds to the Court's Order to Show cause why cases 08-80119,08-80232,08-80380, 08-80993, 08-80381, 08-80994, 08- 80811, 08-80893, 09-80469 and 09-80591 should not be consolidated for discovery purposes:
+
+Plaintiff Jane Doe 101 (Case NO. 09-80591) agrees that all of the ten cases listed above should be consolidated for discovery purposes.
+
+Respectfully submitted,
+
+PODHURST ORSECK, P.A. Attorneys for Plaintiff
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Br No. 040856 rjosefsberg@podhurst.com Katherine W. Ezell Fla. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+## CERTIFICATE OF SERVICE
+
+WE HEREBY CERTIFY that on this I" day of May, 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. Attorneys for Plaintiff
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Br No. 040856 rjosefsberg@podhurst.com Katherine W. Ezell Ha. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+## SERVICE LIST
+
+JANE DOE NO. 101 v. JEFFREY EPSTEIN Case No. 08-CV-80591-MARRA1 United States District Court, Southern District of Florida
+
+Robert Critton, Esq. Burman, Critton, Luther & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 rcrit@bcldlaw.com
+
+Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 jagesq@bellsouth.net
+
+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 Co-counsel for Defendant, Jeffrey Epstein
+
+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.** 
+
+**Adam Horowitz, Esq. Stuart Mermelstein, Esq. Herman & Mermelstein 18205 Biscayne Blvd., Suite 2218 Miami, FL 33160 Phone: (305) 931-2200 Fax: (305) 931-0877 ahorowitz@sexabuseattornev.com**  smermelstein@sexabuseattorney.com
+
+Counsel for Plaintiffs in Related Cases 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 10th 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, LLC
+
+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
+
+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

marker2-fixhub/court-doe-101-v-epstein/EFTA02738164/EFTA02738164.receipt.json

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738171/EFTA02738171.md

@@ -0,0 +1,289 @@
+### IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE No. 101,
+
+Civil Action No. 9:09-cv-80591-KAM
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+FIRST AMENDED COMPLAINT AND Defendant. DEMAND FOR JURY TRIAL
+
+### FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL
+
+Plaintiff, Jane Doe No. 101, brings this Complaint against Defendant, Jeffrey Epstein, and states as follows:
+
+# PARTIES. JURISDICTION, AND VENUE
+
+- 1. At all times material to this cause of action, Plaintiff, Jane Doe No. 101, was a resident of Palm Beach County, Florida.
+- 2. This Complaint is brought under a fictitious name to protect the identity of Plaintiff, Jane Doe No. 101, because this Complaint makes sensitive allegations of sexual assault and abuse of a then minor.
+- 3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida.
+- 4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida. as he is currently incarcerated in the Palm Beach County Stockade.
+- 5. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953.
+
+6. This Court has jurisdiction of this action and the claims set forth herein pursuant to 18 U.S.C. § 2255.
+
+7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(b), as a substantial part of the events giving rise to the claim occurred in this District.
+
+## STATEMENT OF FACTS
+
+8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male, approximately 50 years old. Epstein is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a Boeing 727, as well as a fleet of motor vehicles. Until his incarceration, he maintained his principal place of residence in the largest home in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East Side. Upon information and belief, he also owns a \$6.8 million mansion in Palm Beach, Florida, a \$30 million 7,500-acre ranch in New Mexico he named wlorro," and a 70-acre private island known as Little St. James in St. M, U.S. Virgin Islands, a mansion in London's Westminster neighborhood, and a home in the Avenue Foch area of Paris. The allegations herein concern Defendant's conduct while at his lavish homes and/or numerous other locations both nationally and internationally.
+
+9. Upon information and belief, Defendant has a sexual preference for underage minor girls. He engaged in a plan, scheme, or enterprise in which he gained access in his home to countless relatively economically disadvantaged minor girls, sexually assaulted, molested, and/or exploited these girls, and then gave them money.
+
+10. Beginning in or around 1998 through in or around September 2007, Defendant used his resources and his influence over vulnerable minor children to engage in a systematic pattern of sexually exploitative behavior.
+
+II. Defendant's plan and scheme reflected a particular pattern and method. Defendant coerced and enticed impressionable, vulnerable, and relatively economically less fortunate minors to participate in various acts of sexual misconduct that he committed upon them. Defendant's scheme involved the use of underage girls as well as other individuals to recruit other underage girls. Upon information and belief, Defendant or an authorized agent would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach residence. His assistants would seek out economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered generally \$200 to \$300 per "massage session—and who Defendant and/or his assistants perceived as less likely to complain to authorities or have credibility issues if allegations of improper conduct were made. The then minor Plaintiff and other minor girls, some as young as 14 years old, were transported to Defendant's Palm Beach county mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with "massages."
+
+12. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated with the assistance, support, and facilitation of at least three assistants who helped him orchestrate this child exploitation enterprise. These assistants would often arrange times for underage girls to come to Defendant's residence, transport or cause the transportation of underage girls to Defendant's residence, escort the underage girls to the massage room where Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the conclusion of each "massage appointment," and, upon information and belief, take sexually explicit photographs and/or videos of the underage girls' for Defendant without their knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of dollars.
+
+13. Epstein designed the scheme to secure a private place in Defendant's mansion where only persons employed and invited by Epstein would be present, so as to reduce the chance of detection of Defendant's sexual abuse and prostitution as well as to make it more difficult for the minor girls to flee the premises and/or to credibly report his actions to law enforcement or other authorities. The girls were usually transported by his employees, agents, and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to flee his mansion.
+
+14. Upon arrival at Defendant's mansion, each underage victim would generally be introduced to one of Defendant's assistants, who would gather the girl's personal contact information. The minor girl would then be led up a flight of stairs to a room that contained a massage table and a large shower. The staircase leading to the room was plastered with photographs of nude young girls, including some photographs depicting two or more young girls engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such photographs in each of his four homes and on his computer.
+
+15. At times, if it was the girl's first "massage" appointment, another female would be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant would start his massage wearing only a small towel, which eventually would be removed. Defendant and/or the other female would direct the girl to massage him, giving the minor girl specific instructions as to where and how he wanted to be touched, and then direct her to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including masturbation, fondling the minor's breasts and/or sexual organs, touching the minor's vulva, vagina, and/or anus with a vibrator and/or back massager and/or his finger(s) and/or his penis, digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex, and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution and/or enticing the then minor girl to engage in sexual acts with another female in Defendant's presence. The exact degree of molestation and frequency with which the sexual crimes took place varied and is not yet completely known; however, at least when Defendant was in Palm Beach, Florida, such acts occurred usually on a daily basis and, in most instances, several times a day. In order to facilitate the daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency readily available.
+
+16. As previously stated in paragraph 14, Defendant displayed photographs of nude underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and belief, some of the photographs Defendant's possession of Defendant were taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement.
+
+17. Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to contact these minor girls for the purpose of coercing them into acts of prostitution and to enable himself to commit sexual battery against them and/or acts of lewdness in their presence, and he conspired with others, including assistants and/or his driver(s) and/or pilot(s), and his socialite
+
+friend/partner, Ghislaine Maxwell, to further these acts and to avoid police detection. Defendant's systematic pattern of sexually exploitative behavior referred to in paragraph 10 and described in paragraphs 11 through the present paragraph occurred at all of Defendant's domestic and international residences and/or places of lodging and/or modes of transportation.
+
+18. Consistent with the foregoing plan and scheme, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff. Plaintiff, Jane Doe No. 101, was recruited by one of Defendant's agents to give Defendant a massage for compensation. Plaintiff was apprehensive, but needed the money and finally agreed to go. Plaintiff was first brought to Defendant's mansion in or about the spring of 2003, when she was merely 17 years old and in high school. Epstein's procurer drove her to Jeffrey Epstein's mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a shower and a massage table, where she was left alone. A woman with dark hair, an accent, and naked from the waist up entered and tried to coax Plaintiff to remove her shirt, but Plaintiff refused. After the woman showed Plaintiff how to use the lotions that were there, the woman left. Defendant walked in wearing only a small towel. He lay down on the massage table still wearing the small towel, and Plaintiff began to massage his shoulders and neck. Nervously, she asked him what he did for a living. Defendant responded that he was a scientist. Defendant asked Plaintiff what year she would graduate high school, to which Plaintiff honestly replied that she would graduate in 2004. Plaintiff massaged Defendant's lower back and calves. Defendant told her to remove his towel. Defendant told her that he had just worked out and wanted his buttocks massaged. Although disgusted, she was afraid to refuse and did it. At some point, Defendant ordered Plaintiff to remove her clothes. In shock, fear, and trepidation, Plaintiff partly complied, removing only her shirt and bra. When Defendant turned over, Plaintiff was afraid and embarrassed and she wanted to leave. Defendant repeatedly told her to relax and
+
+complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to him. He began masturbating and then began fondling her breasts. He asked her to do more and mentioned more money, which she adamantly declined. Defendant continued masturbating until he ejaculated. Plaintiff next recalls that she received \$200 and was transported by the procurer, whom she later learned received \$200 for having brought her to Epstein's mansion.
+
+19. Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer made another appointment for her to return, but Plaintiff didn't want to see Defendant. By having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon each instance of contact and/or abuse.
+
+20. In addition to the direct sexual abuse and molestation of the then minor Plaintiff, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff to bring him another minor girl in a promised exchange for money. Rather than go herself, Plaintiff and the procurer took another girl there one time.
+
+21. As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 101, has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's controlling and manipulating her into a perverse and unhealthy way of life.
+
+22. Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by her telling him her high school graduation year, as well as his own actions, and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual
+
+exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiffs age of minority. Defendant's preference for underage girls was well-known to those who regularly procured them for him.
+
+23. Defendant, Jeffrey Epstein, committed the above-referenced acts upon the then minor Plaintiff in violation of federal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, transport of child pornography, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(b), § 2423(e), § 2251, § 2252, § 2252A(a)(1), and § 2252A(gX1).
+
+24. In June 2008, after investigations by the Palm Beach Police Department, the Palm Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe No. 101. Plaintiff hereby exclusively seeks civil remedies pursuant to 18 U.S.C. § 2255.
+
+### COUNT ONE (Cause of Action for Coercion and Enticement of Minor to Engage in Prostitution or Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2422(14)
+
+25. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above.
+
+26. Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign commerce to knowingly persuade, induce, entice, or coerce Jane Doe No. 101, when she was under the age of 18 years, to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense, or attempted to do so, pursuant to l8 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b).
+
+27. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+28. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant. Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation. actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+#### COUNT TWO (Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2423(b))
+
+29. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above.
+
+30. Upon information and belief, Defendant, Jeffrey Epstein. traveled in interstate and/or foreign commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, including the then minor Plaintiff, in violation of 18 U.S.C. § 2423(b).
+
+31. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+32. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+#### COUNT THREE (Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2251)
+
+33. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above.
+
+34. Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the then minor Plaintiff, Jane Doe No. 101, to engage in sexually explicit conduct for the purpose of producing a visual depiction of such conduct in violation of 18 U.S.C. § 2251. As previously stated in paragraphs 14 and 16, Defendant displayed a myriad of photographs of underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more sexually explicit photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement.
+
+35. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+36. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+#### COUNT FOUR (Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit Conduct pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2252(a)(1))
+
+37. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above.
+
+38. Defendant, Jeffrey Epstein, upon information and belief, knowingly mailed, transported, shipped, or sent via computer and/or facsimile in or affecting interstate or foreign commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit conduct in violation of 18 U.S.C. § 2252(a)(1). As previously stated in paragraphs 14, 16, and 34, upon information and belief, Defendant displayed a myriad of nude photographs of underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more sexually explicit photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement.
+
+39. As previously stated in paragraph 22, any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse
+
+of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiffs age of minority. Defendant's preference for underage girls was well-known to those who regularly procured them for him.
+
+40. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+41. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+#### COUNT FIVE (Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2252A(a)(1))
+
+42. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above.
+
+43. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via computer or facsimile in or affecting interstate and/or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1). As previously stated in paragraph 16, Defendant displayed a myriad of nude photographs of underage girls throughout his homes, including his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and nude photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement.
+
+44. As previously stated in paragraph 22, any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew
+
+and should have known of Plaintiff's age of minority. Defendant's preference for underage girls was well-known to those who regularly procured them for him.
+
+45. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+46. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+#### COUNT SIX (Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. 2255 in Violation of 18 U.S.C. § 2252A(2))
+
+47. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above and Counts One through Five.
+
+48. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, as defined in 18 U.S.C. § 2252A(gX2), in violation of 18 USC § 2252A(g)(1). As more fully above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 1591 (sex trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 U.S.C. §§ 2251, 2252(a)(1), and 2252(A)(a)(1)), and Chapter 117 (transportation for illegal sexual activity in violation of 18 U.S.C. §§ 2422, and 2423). As more fully set forth above in paragraphs 9 through 19, Defendant's actions involved countless victims and countless separate incidents of abuse, and he committed those offenses against minors in concert with at least three other persons.
+
+49. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.
+
+50. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish. humiliation. confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
+
+Date: May 1, 2009
+
+s/Katherine W. Ezell Robert C. Josefsberg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) rjosefsberg@podhurst.com keza@podhurst.com
+
+Attorneys for Plaintiff
+
+# DEMAND FOR JURY TRIAL
+
+Plaintiff demands to have her case tried before a jury.
+
+s/Katherine W. Ezell
+
+Robert C. Josefsberg, Bar No. 040856
+
+Katherine W. Ezell, Bar No. 114771
+
+Podhurst Orseck, P.A.
+
+25 West Hagler Street, Suite 800
+
+Miami, Florida 33130
+
+(305) 358-2800
+
+(305) 358-2382 (fax)
+
+rjosefsberg@podhurst.com
+
+kezell@podhurst.com
+
+Attorneys for Plaintiff
+
+#### CERTIFICATE OF SERVICE
+
+WE HEREBY CERTIFY that on this In day of May, 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. Attorneys for Plaintiff
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Ha. Br No. 040856 rjosefsberg@podhurst.com Katherine W. Ezell Fla. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+## SERVICE LIST
+
+JANE DOE NO. 101 v. JEFFREY EPSTEIN Case No. 08-CV-80591-MARRa United States District Court, Southern District of Florida
+
+Robert Critton, Esq. Burman, Critton, Luttier & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 rcrit@bcldlaw.com
+
+Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 jagesq@bellsouth.net
+
+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 Co-counsel for Defendant, Jeffrey Epstein
+
+Jack Scarola, Esq. Jack P.M, 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 iph@searcylaw.com Counsel for Plaintiff C.M.A.
+
+Adam Horowitz, Esq. Stuart Mermelstein, Esq. Herman & Mermelstein 18205 Biscayne Blvd. Suite 2218 Miami, FL 33160
+
+Phone: (305) 931-2200
+
+Fax: (305) 931-0877
+
+ahorowitz@sexabuseattomey.com
+
+smermelstein@sexabuseattomey.com
+
+Counsel for Plaintiffs in Related Cases 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'h Ave North, Suite 404
+
+Lake Worth, FL 33461
+
+Phone: (561) 582-7600
+
+Fax: (561) 588-8819
+
+lawyerwillits@aol.com
+
+reelrhw @ hotmai I .com
+
+Counsel for Plaintiff in Related Case No. 08-80811
+
+Brad , Esq.
+
+Law Office of Brad & Associates, LLC
+
+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
+
+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

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738193/EFTA02738193.md

@@ -0,0 +1,125 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARIOVJOHNSON
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## NOTICE OF STRIKING DOCKET ENTRY
+
+Plaintiff, JANE DOE No. 101, hereby gives notice of striking Docket Entry Number [7], which was inadvertently filed without a signature. The document has been re-filed correctly [D.E. 9].
+
+Dated this day of May, 2009.
+
+Respectfully submitted,
+
+PODHURST ORSECK, P.A. Attorneys for Plaintiff
+
+By: 5/Katherine W. Ezell Robert C. Josefsbcrg Fla. Br No. 040856 rjosefsberaiwdburst,com Katherine W. Ezell Fla. Bar No. 114771 kezelltlipodhurst.coni City National Bank Building 25 W. Flaglcr Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+## CERTIFICATE OF SERVICE
+
+WE HEREBY CERTIFY that on this 4th day of May, 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. Attorneys for Plaintiff
+
+By: p/Katherine W. Ezell Robert C. Joscfsberg Fla. Br No. 040856 rioscfshergfitpodhurst.com Katherine W. Ezell Ha. Bar No. 114771 kezelblipodhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+## SERVICE LIST
+
+JANE DOE NO. 101 v. JEFFREY EPSTEIN Case No. 08-CV-80591- United States District Court, Southern District of Florida
+
+Robert Critton, Esq. Burman, Critton, Luther & Coleman LLP 515 North FlagJer Drive, Suite 400 West Palm Beach, FL 33401 rcrit@bcldlaw.com
+
+Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 jagesa @bel Isouth. net
+
+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 ecUbrucereinhartlaw.com Co-counsel for Defendant, Jeffrey Epstein
+
+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@scarcylaw.com jph@searcvlaw.com Counsel for Plaintiff C.M.A.
+
+Adam Horowitz, Esq. Stuart Mermelstein, Esq. Herman & Mermelstein 18205 Biscayne Blvd., Suite 2218 Miami, FL 33160 Phone: (305) 931-2200 Fax: (305) 931-0877
+
+phorowitz@sexabuseattomev.com
+
+,mermelstein@sexabuseattomey.cona
+
+Counsel for Plaintiffs in Related Cases Nos. 0840069, 0840119,08-80232, 0840380, 08- 80381, 0840993, 0840994
+
+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@leonoldkuvin.corn
+
+tleopold@leopoldkuvin.cont
+
+Counsel for Plaintiff in Related Case No. 08-08804
+
+Richard Willis, Esq.
+
+Richard H. Willits, P.A.
+
+2290 10\*Ave North, Suite 404
+
+Lake Worth, FL 33461
+
+Phone: (561) 582-7600
+
+Fax: (561) 588-8819
+
+lawverwillitsqaol.com
+
+reelrhw@hottnail.com
+
+Counsel for Plaintiff in Related Case No. 08-80811
+
+Brad S Esq.
+
+Law Office of Brad & Associates, LLC
+
+2028 Street, Suite 202
+
+Hollywood, FL 33020
+
+Phone: (954) 414-8033
+
+Fax: (954) 9241530
+
+bedwardserra-law.com
+
+be@bradedwardslaw.corn
+
+Counsel for Plaintiff in Related Case No. 0840893
+
+Isidro Manuel =, Esq.
+
+Elkins & Boehringer
+
+224 Datura Avenue, Suite 900
+
+West Palm Beach, FL 33401
+
+Phone: (561) 832-8033
+
+Fax: (561) 832-7137
+
+jsidroaarcia@bellsouth.net
+
+Counsel for Plaintiff in Related Case No. 0840469

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738197/EFTA02738197.md

@@ -0,0 +1,66 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 09-80591-MARRAIJOHNSON
+
+JANE DOE No. 101,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant,
+
+## DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO COMPLAINT
+
+Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned attorneys, respectfully moves this Court for an extension of time in which to respond to Complaint dated, April 17, 2009. Defendant seeks an extension until May 26, 2009, to file his response. As good cause in support of granting the motion, Defendant states:
+
+- 1. On April 17, 2009 Plaintiff filed a Complaint [DE 1]. Defendant's response would be due on May 11, 2009.
+- 2. There are several other cases filed with this Court in which Jeffrey Epstein is named a Defendant. In those cases, the undersigned has been preparing responses to Motions for Protective Order and handling other matters associated therewith.
+- 3. Additionally, Defendant's counsel is in the midst of preparing for a state court trial, CARDIOPULMONARY & PRIMARY CARE ASSOC. OF TREASURE COAST, P.A
+- v. =, M.D., Case No. 562008CA001726, specially set for trial beginning May 13
+
+Doe 101 v. Epstein Page 2
+
+through 15, 2009). Discovery in that case is ongoing with several depositions set to prepare for trial.
+
+4. The requested extension is fair in reasonable under the circumstances as it will provide time to allow the Defendant, EPSTEIN, to fully and adequately respond.
+
+5. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiffs counsel is in agreement with the requested extension.
+
+WHEREFORE Defendant respectfully requests that this Court enter an order granting an extension until May 26, 2009, to file a response to Plaintiff's Complaint.
+
+## Local Rule 7.1 Statement
+
+Counsel for the movant conferred by telephone and correspondence with counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested extension until May 26, 2009 for Defendant to r fnd t aintiff's Complaint.
+
+> Robe I Critto , Esq. Attorney for Defendant
+
+## Certificate of Service
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of re d identified on the following Service List in the manner specified by CM/ECF on this day of May, 2009
+
+Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382
+
+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
+
+Doe 101 v. Epstein  
+Page 3
+
+[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com)  
+[kezell@podhurst.com](mailto:kezell@podhurst.com)  
+*Counsel for Plaintiff*
+
+[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net)  
+*Counsel for Defendant Jeffrey Epstein*
+
+MICHAEL J. PIKE, ESQ.  
+Florida Bar #617296  
+[mpike@bclclaw.com](mailto: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)*

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738200/EFTA02738200.md

@@ -0,0 +1,75 @@
+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 09-80591-MARRAMM
+
+JANE DOE No. 101,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant,
+
+#### DEFENDANT EPSTEIN'S RESPONSE IN OPPOSITION TO THIS COURT'S ORDER TO SHOW CAUSE AS WHY ALL CASES SHOULD NOT BE CONSOLIDATED FOR DISCOVERY PURPOSES AND MOTION TO CLARIFY THE COURT'S ORDER DATED APRIL 28, 2009
+
+Defendant, JEFFERY EPSTEIN, (EPSTEIN), by and through his undersigned attorneys, hereby files his Response in Opposition to this Court's Order to Show Cause as to Why All Cases Should Not be Consolidated for Purposes of Discovery and Motion for Clarification of this Court's Order on general consolidation of discovery (DE 6), and states:
+
+# I. Response In Opposition
+
+Defendant has no further objections to consolidating these cases for purposes of depositions as outlined in this Court's April 28, 2009 Order.
+
+However, to consolidate the cases for purposes of all "discovery" including, but not limited to, motion practice and related orders thereto will, without question, confuse many of the individual discovery issues raised not only by Epstein as to the individual Plaintiffs that have brought separate lawsuits against him, but will also confuse the
+
+individual discovery issues raised by those same individual Plaintiffs as to Epstein. This will undoubtedly lead to several motions to clarify certain orders which will seek explanation from the court as to how those orders affect Epstein as to each individual Plaintiff's discovery requests and vice versa (i.e., how those future orders affect the individual Plaintiffs' discovery requests directed to Epstein).
+
+It is important to note that each related Federal matter before this court has its very own distinct set of facts and defenses thereto. In fact, this is the newly most filed cause of action against Epstein, and, as such, a separate discovery schedule is warranted. The discovery served and the responses received are particular and individualized as to both Plaintiff and Defendant. As such, discovery of "all" cases for general discovery consolidation (separate and apart from depositions) will only cloud rulings on discovery and will result in more attorney labor and judicial resources, which will inevitably be spent on motions for clarification.
+
+Each Plaintiff and Epstein have served and will in the future serve separate requests for production, separate interrogatories, separate requests for admissions, and separate motions to compel, responses and replies addressing certain discovery issues. Obviously, both Plaintiff and Defendant will base their discovery related arguments on the particularized facts of each case, which are separate and distinct from one another. Moreover, the Plaintiffs will likely seek to retain different experts to support their individual claims. In that regard, how will a general consolidation of discovery impact discovery related to those experts' individualized opinions?
+
+As this court is aware, certain case management orders are in place setting the parameters of discovery. It is unclear how Plaintiffs' Motion to Consolidate and the
+
+Courts Order will handle the potential problems and any other potential discovery related issues outlined above. In fact, it appears that Jane Doe, in Case No. 08-CV-80893 (DE 47), has expressed her own reasons for opposing the consolidation all the cases for discovery purposes. Obviously, Jane Doe's counsel, like the undersigned, anticipates that discovery issues will present themselves if general consolidation occurs and does not want it to impact her case. In fact, the debates have already begun in light of this Court's April 29, 2009 Order and the responses filed addressing same. This provides the court with a glimpse of what will occur if general consolidation occurs, in particular, how attorney resources and judicial resources will be unnecessarily used.
+
+In addition, the initial style of each case should be maintained in pleadings and in orders in an effort to maintain organization and application of the rulings this court espouses for each case. Utilizing a compound multiple-type style will only confuse cases that should be kept separate for all discovery purposes.
+
+# II. Motion for Clarification of this Court's April 28, 2009 Order
+
+This Court ruled that cases 08-80119, 08-80232, 08-80380 and 08-80993 are consolidated for discovery purposes. Epstein not only objects to the court's consolidation order but seeks clarification from this Court as to how consolidation of general discovery will impact motion practice and orders in the above cases. What does the court mean when it says the above cases are consolidated "for purposes of discovery only?" How does consolidation operate? The concerns addressing general discovery consolidation are set out above and are therefore incorporated herein. Likewise, for those reasons, the court should reverse its ruling on consolidation and issue a new order maintaining the individuality of each case for discovery purposes.
+
+In addition, Epstein not only objects to the court's potential consolidation of case numbers 08-80381, 08-80994, 08-80811, 08-80893, 09-80469 and 09-80591 for general discovery purposes, but respectfully requests that this court clarify how consolidation of general discovery will impact motion practice and orders in the above cases should this court choose to consolidate same for discovery. Again, how does consolidation operate? The concerns addressing general discovery consolidation are set out above and are therefore incorporated herein.
+
+In short, the Motions seeking consolidation for discovery purposes only do not delineate how consolidation operates. As such, the Order granting the Motions to Consolidate for discovery purposes only does not provide any additional information addressing how consolidation will operate.
+
+WHEREFORE, Defendant requests that this Court not consolidate case numbers 08-80381, 08-80994, 08-80811, 08-80893, 09-80469 and 09-80591, that it clarify its order as to consolidation of case numbers 08-80119, 08-80232, 08-80380 and 08-80993 (or the future consolidation of other cases) and that it reverse its April 28, 2009 ruling on general consolidation in light of the potential problems presented in this response, that an order be entered requiring the parties to utilize the style secured by the initial case filing and not a compound-case style incorporating all case styles in one particular document, and for such other and further relief as this Court deems just and proper.
+
+**Certificate of Service**
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+
+served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 4 day of May, 2009
+
+Robert C. Josefsberg, Esq.  
+Katherine W. Ezell, Esq.  
+Podhurst Orseck, P.A.  
+25 West Flagler Street, Suite 800  
+Miami, FL 33130  
+305 358-2800  
+Fax: 305 358-2382  
+[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com)  
+[kezell@podhurst.com](mailto:kezell@podhurst.com)  
+*Counsel for Plaintiff*
+
+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](mailto:jagesq@bellsouth.net)  
+*Counsel for Defendant Jeffrey Epstein*
+
+Respectfully submitted,
+

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738205/EFTA02738205.md

@@ -0,0 +1,63 @@
+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE No. 101,
+
+Civil Action No.
+
+Plaintiff,
+
+vs.
+
+JEFFREY EP=,
+
+Defendant.
+
+## MOTION TO PROCEED ANONYMOUSLY AND INCORPORATED MEMORANDUM OF LAW
+
+Plaintiff, Jane Doe No. 101, by and through her undersigned counsel, moves this Court to enter an Order granting Plaintiff permission to proceed in this action under the pseudonym "Jane Doe No. 101" and, as grounds, states as follows:
+
+- 1. As outlined in detail in the Complaint, Jane Doe No. 101 was sexually abused by Defendant, Jeffrey Epstein, when she was under the age of 18.
+- 2. As a result of Defendant's sexual abuse, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life.
+- 3. Disclosure of Plaintiff's name would cause her much additional embarrassment, humiliation, and psychological trauma.
+
+4. The subject matter of the Complaint clearly contains highly sensitive and intimate information about Plaintiff.
+
+5. Plaintiff was an identified victim by the FBI and the U.S. Attorney's Office in a criminal investigation against Defendant, Jeffrey Epstein.
+
+6. During the related criminal investigation, and up and to this point in time, Plaintiff's identity has been sealed, as all parties recognize the highly sensitive subject matter of the charges and the need to protect the privacy interest of Plaintiff's identity.
+
+7. In this civil action, Defendant, Jeffrey Epstein, already knows Plaintiff's identity and will be privy to the sealed document containing Plaintiff's name. 'Therefore, he knows the identity of Plaintiff and will not be prejudiced by public non-disclosure of Jane Doe No. 101's identity.
+
+8. There is great need, in this case, to protect intimate information about Plaintiff, Jane Doe No. 101, and to protect her privacy interest.
+
+## Memorandum of Law
+
+The general presumption against anonymous or pseudonymous pleadings is commonly overcome in certain types of cases, and courts have discretion to permit such pleading in appropriate circumstances. "[P]rivacy or confidentiality concerns are sometimes sufficiently critical that parties or witnesses should be allowed this rare dispensation." James v. Jacobson, 6 F.3d 233, 238 (4th Cir. 1993). As is ordinarily the case where trial courts have discretion, judicial guidelines exist for the exercise of such discretion in the form of factors that courts should consider in deciding whether to grant anonymity requests. They are not many, for the question happily is one that is seldom raised. Nevertheless, some guidelines can be gleaned from the relatively few cases—both at the trial and appellate levels—that have wrestled with the problem. Among them are the following that have relevance to this case: whether the
+
+justification asserted by the requesting party is merely to avoid the annoyance and criticism that may attend any litigation or to preserve privacy in a matter of sensitive and highly personal nature; whether identification poses a risk of retaliatory physical or mental harm to the requesting party or, even more critically, to innocent non-parties; the ages of the persons whose privacy interests arc sought to be protected; and, rclatedly, the risk of unfairness to the opposing party from allowing an action against it to proceed anonymously. See id. (internal citations omitted).
+
+In deciding whether to permit pseudonymous pleadings, courts must balance "the plaintiff's right to privacy and security against the dual concerns of (1) public interest in identification of litigants and (2) harm to the defendant stemming from [suppression] of plaintiff's name." Doe v. M, 105 F. Supp. 2d 40, 44 (E.D.N.Y. 1999) (internal citation omitted). The ultimate test for permitting a plaintiff to proceed anonymously is whether the plaintiff has a substantial privacy right that outweighs the customary presumption of openness in judicial proceedings. See Doe v. Stegall, 653 F.2d 180, 185-86 (5th Cir. August 10, 1981). Courts typically accept pseudonym filing in cases where the nature of the pleading unveils highly sensitive information and detail about the plaintiff, such that the non-disclosure of the party's name is necessary to protect her from harassment, injury, ridicule, or personal embarrassment. See United States v. Doe, 655 F.2d 920, 922 n.1 (9th Cir. 1981); see also Doe v. 429 F.3d 706 (7th Cir. 2005) (court required to consider whether the interests of justice required adult woman, who was videotaped having consensual sex with her boyfriend when she was a minor, to disclose her name as plaintiff in lawsuit against boyfriend alleging that boyfriend illegally distributed videotape); Does 1 Thru XXIII v. Advanced 'Textile Corp., 214 F.3d 1058, 1067-68 (9th Cir. 2000) (district court abused its discretion in denying permission to proceed anonymously to Chinese employees working in garment industry in Mariana Islands where
+
+employees were vulnerable to retaliation); Stegall, 653 F.2d at 185-86 (anonymity warranted to protect minor plaintiffs against risk of violence from revelation of unpopular personal beliefs); Doe v. United Servs. Life Ins. Co., 123 F.R.D. 437 (S.D.N.Y. 1988) (anonymity allowed because of sensitive privacy and retaliation concerns in suit by homosexual against insurance company alleging discriminatory practices; no unfairness to defendant, who was aware of claimant's identity); Candy H. v. Redemption Ranch, 563 F. Supp. 505 (M.D. Ala. 1983) (anonymity allowed in suit by pregnant 19-year-old alleging fraudulent inducement to enter defendant's Home for Girls).
+
+It is clear from the allegations of sexual abuse of a minor in the Complaint that the information is of a highly sensitive nature. Jane Doc No. 101's name remained anonymous in the related criminal case, and Defendant's attorneys, as well as the United States government, redacted all documents containing her name. The present case is not one in which permitting Plaintiff to proceed anonymously will disadvantage Defendant in any way. Defendant already knows Plaintiff's identity and will be privy to the sealed document containing Plaintiffs name. While the public normally has a right to the openness of judicial proceedings, the victim's privacy interest greatly outweighs the right to know the identity of a victim of child sex abuse. Other than the identity of Plaintiff, the aspects of this case will be available to the public. Evidently, the balance weighs overwhelmingly in favor of allowing Plaintiff to proceed anonymously.
+
+This Court recently has allowed at least ten other plaintiffs who were underage sex abuse victims of Defendant, Jeffrey Epstein, to proceed anonymously. See C.M.A. v. Epstein et al., Case No. 9:08-cv-80811-KAM; Jane Doe No. 1 v. Epstein, Case No. 9:08-cv-80069-KAM; Jane Doe No. 2 v. Epstein, Case No. 9:08-ov-80119-1(AM; Jane Doe No. 3 v. Epstein, Case No. 9:08-cv-800232; Jane Doe No. 4 v. Epstein, Case No. 9:08-cv-80380-KAM; Jane Doe No. 5 v.
+
+Epstein, Case No. 9:08-cv-80381-KAM; Jane Doe No. 6 v. Epstein, Case No. 9:08-cv-80994- KAM; Jane Doe No. 7 v. Epstein, Case No. 9:08-cv-80993-KAM; Jane Doe v. Epstein, Case No. 9:08-ev-80893-KAM; Jane Doe v. Epstein et at, Case No. 9:08-cv-80804-KAM; Jane Doe v. Epstein, Case No. 9:08-cv-80469-KAM. Accordingly, this Court should likewise permit Jane Doe No. 101 to proceed anonymously.
+
+WHEREFORE, Plaintiff, Jane Doe No. 101, moves this Court to enter an Order granting this Motion, thus allowing her to proceed in this litigation under the Jane Doe No. 101 pseudonym.
+
+Date: April 17, 2009
+
+Rpm C. co-J-444r, Robert C. Josefsbe-g, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Nagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) rjosefsberg(a)podhurst.com kezellapodhurst.com
+
+Attorneys for Plaintiff
+
+## CERTIFICATE OF COMPLIANCE WITII LOCAL RULE 7.1.A.3
+
+On April 1, 2009, undersigned counsel conferred with counsel for Defendant in a good faith effort to resolve the issues raised in this motion, and Defendant's counsel advised that Defendant opposes this motion.
+
+Date: April 17, 2009
+
+ROBERT C. JOS SBE G t C- 1—sscis A—te Florida Bar No. 040856

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738210/EFTA02738210.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JA/4E DOE NO. 101, CASE NO.: 09-CV-80591-MARRa
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## NOTICE OF FILING
+
+Plaintiff, JANE DOE No. 101, hereby gives notice of filing Motion to Proceed Anonymously and Incorporated Memorandum of Law, which was filed in the conventional manner with the Court on April 17, 2009, along with the Summons and Complaint. Plaintiff inadvertently omitted said motion when the initial documents were served on Defendant's counsel.
+
+Dated this ho day of May, 2009.
+
+Respectfully submitted,
+
+PODHURST ORSECK, P.A. Attorneys for Plaintiff
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Br No. 040856 rjosefsberg@podhurst.com Katherine W. Ezell Fla. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130
+
+Telephone: (305) 358-2800
+
+Facsimile: (305) 358-2382
+
+## CERTIFICATE OF SERVICE
+
+WE HEREBY CERTIFY that on this 6th day of May, 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. Attorneys for Plaintiff
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Br No. 040856 rjosefsberg@podhurst.coni Katherine W. Ezell Fla. Bar No. 114771 kezellepodhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+## SERVICE LIST
+
+JANE DOE NO. 101 v. JEFFREY EPSTEIN Case No. 08-CV-80591- United States District Court, Southern District of Florida
+
+Robert Critton Esq. Burman, Critton, Luttier & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 rcrit(tbeldlaw.com
+
+Jack Goldberger, Esq. Atterbtuy, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 japesa@bellsouth.net
+
+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 Co-counsel for Defendant, Jeffrey Epstein

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738213/EFTA02738213.md

@@ -0,0 +1,42 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 09-80591-MARRa
+
+JANE DOE No. 101,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant,
+
+## NOTICE OF APPEARANCE
+
+The undersigned attorneys hereby file an appearance as counsel on behalf of the Defendant, JEFFREY EPSTEIN, in the styled matter.
+
+> By: RO ERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 rcrit bciclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpikeebciclaw.com
+
+## Certificate of Service
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this day of May, 2009
+
+Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400
+
+Doe 101 v. Epstein  
+Page 2
+
+Miami, FL 33130  
+305 358-2800  
+Fax: 305 358-2382  
+[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com)  
+[kezell@podhurst.com](mailto:kezell@podhurst.com)  
+Counsel for Plaintiff
+
+West Palm Beach, FL 33401-5012  
+561-659-8300  
+Fax: 561-835-8691  
+[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net)  
+*Counsel for Defendant Jeffrey Epstein*
+

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738215/EFTA02738215.md

@@ -0,0 +1,140 @@
+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 09-80591-MARRa
+
+JANE DOE No. 101,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant,
+
+# RESPONSE IN OPPOSITION TO MOTION TO PROCEED ANONYMOUSLY
+
+### AND
+
+#### EPSTEIN'S MOTION TO COMPEL AND/OR IDENTIFY JANE DOE #101 IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE #101 IN THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY. WITH INCORPORATED MEMORANDUM OF LAW
+
+Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and through his undersigned attorneys, hereby files his Response In Opposition to Plaintiff, Jane Doe #101's Motion to Proceed Anonymously and files his Motion requesting that this Court enter an order identifying in the style of this case the complete legal name of the Plaintiff, JANE DOE #101 ("JANE DOE"), to substitute her complete legal name in this case in place of "JANE DOE" and, equally important, allowing Defendant to identify her in various subpoenas that Epstein must serve so Epstein can defend this case. In support, Mr. Epstein states as follows:
+
+### I. Response In Opposition With Incorporated Motion And Incorporated Memorandum Of Law
+
+# a. Background
+
+1. On April 17, 2009, Plaintiff filed this action against Epstein. The Complaint (DE 1) alleges three causes of action against him: Count I - Coercion and Enticement of a Minor to Engage in Prostitution or Sexual Activity Pursuant to 18 U.S.C. §§2255 and 2422(b); Count II — Cause of Action for Travel With Intent to Engage in Illicit Sexual Conduct Pursuant to Pursuant to 18 U.S.C. §§2255 and 2423(b); Count III — Cause of Action for Sexual Exploitation of Children Pursuant to 18 U.S.C. §§2255 and 2251(b); Count IV - Cause of Action for Visual Depiction of Minor Engaging in Sexually Explicit Conduct Pursuant to 18 U.S.C. §§2255 and 2251(a)(1); Count V — Cause of Action for Transport of Child Pornography Pursuant to 18 U.S.C. §§2255 and 2252A(a)(1); and Count VI — Cause of Action for Engaging in a Child Exploitation Enterprise Pursuant to 18 U.S.C. §§2255 and 2252A(g).
+
+2. Plaintiff alleges, among other things, that she is entitled to money damages pursuant to 2255 (in the wherefore clause), as well as actual and compensatory.
+
+3. Obviously, Plaintiff alleges separate counts against Mr. Epstein, on which he must conduct discovery to defend this case. Therefore, for the reasons set forth herein, not only must JANE DOE'S Motion to Proceed Anonymously be denied, but Epstein's Motion to Identify Jane Doe must be granted. Despite Plaintiff's allegations in the Motion to Proceed Anonymously, this Court has not "allowed" any Plaintiff to proceed anonymously. Quite simply, that is the way
+
+each Plaintiff chose to file each of their respective cases, all of which are currently being challenged in those other matters by Motion to Identify.
+
+4. Importantly, JANE DOE claims that she has and will suffer . .physical injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy . . . , and medical and psychological expenses. . . , loss on income, loss of the capacity to earn income in the future, and loss of the capacity to enjoy life" ¶¶28, Comp., DE 1; see also ¶¶32, 36, 41, 46 and 50, Comp., DE 1.
+
+5. Epstein has a constitutional due process right to defend himself and to seek the production of information that will assist in his defense of the allegations in the Complaint. In this case, Plaintiff's counsel intends on serving subpoenas on Plaintiff's treating physicians and other third parties. Thus, this motion seeks not only a denial Plaintiff's Motion to Proceed Anonymously but to identify JANE DOE in the style of this case and to identify JANE DOE in various third-party subpoenas for discovery purposes.
+
+6. The undersigned's experience in "Jane Doe" lawsuits is that once a Plaintiff is identified, other individuals come forward in the discovery phase with information which often directly contradicts allegations as to the events and damages. For instance, witnesses may testify that Plaintiff was paid by others for similar sexual acts she claims Mr. Epstein forced upon her or that she willingly participated in certain act(s) that would negate or lessen her damages. This goes directly to Plaintiffs damage claim.
+
+7. Likewise, subpoenas must be issued to third-party treaters and current and former employers, and those subpoenas will seek to obtain records related directly to Plaintiffs claims and her damages (i.e., her claim for severe and permanent traumatic injuries, including mental, psychological and emotional damages and loss of self-esteem as referenced above). Cherenfant v. Nationwide Credit, Inc., 2004 WL 5315889 (S.D. Fla. 2004)(order allowing discovery of medical records consistent with Plaintiffs allegations in complaint). This too goes directly to Plaintiff's damage claims. Medical providers, employers, co-employees, etc... have direct and relevant personal knowledge and observations regarding damages, i.e., emotional state, activities, self-esteem, etc....
+
+8. Fed.R.Civ.Pro. 26 allows for broad discovery. Epstein is not required to rely solely on Plaintiffs discovery responses in defending this case, nor is Epstein required by any statute or law to rely only upon what Plaintiff may produce in discovery or may obtain from her own medical treaters through her counsel, and to then provide to Epstein only after Plaintiff has reviewed same. In certain related state court actions involving Epstein, the undersigned offered to serve certain subpoenas on the medical treaters and other third-parties with full name, date of birth and Plaintiffs social security number (last four digits), but agreed that the subpoenas filed with the clerk would be redacted. Several attorneys agreed to this procedure in those cases. In Federal Court, subpoenas are not filed with the clerk. Thus, in this matter, the undersigned offered to serve the third-party subpoenas with plaintiffs full name, date of birth and social security number (last four digits) and would agree to redact any identifying information on any documents filed with this court if that ultimately became necessary.
+
+9. Moreover, when an order from the court is attached to the Subpoena, treaters and other third parties produce the records and show up to the depositions with the records requested because the deponent knows what to bring by virtue of knowing the identity of the Plaintiff.
+
+10. Epstein's counsel intends to serve and depose witnesses duces tecum. If Epstein is not permitted to identify JANE DOE (thus allowing her to proceed anonymously), how will any deponent know who the parties are and what to bring to the deposition pursuant to the duces tecum? Further, how will Epstein be able to defend the claims. Just like the Plaintiff, Epstein is entitled to due process. If the Court allows Jane Doe to proceed anonymously, Jane Doe will be permitted to present her case and Epstein will be limited in his defenses.
+
+11. While it is within the sound discretion of this court to allow a party to proceed anonymously, Plaintiff should not attempt to utilize that discretion as a shield from legitimate and necessary discovery. Epstein has a fundamental due process right to conduct discovery.
+
+## b. Response in Opposition And Motion To Identify JANE DOE In Style Of This Case
+
+12. As discussed below, Epstein has fundamental due process right to defend himself in this civil litigation. While JANE DOE travels under a pseudonym, various newspaper articles identifying Epstein have been released discussing the alleged claims against him. Allowing JANE DOE to litigate this
+
+matter under a pseudonym is preventing Epstein from defending this suit including, but not limited to, preventing him from locating individuals that may have information about this lawsuit and information about JANE DOE that may discredit her allegations and/or lessen the monetary damages she seeks to recover. It is the undersigned's experience that once identified, witnesses begin to come forward. See supra.
+
+13. In Doe v. Lepley, 185 F.R.D. 605 (D. Ct. NV 1999), a sexual harassment case, the court reasoned that there is no express or implied right to bring an action anonymously. Id. at 606. Moreover, Fed. R. Civ. P 10(a) requires that the complaint include the names of the parties. Id. When Plaintiffs are permitted to proceed anonymously, the court must employ a balancing test to decide if the plaintiff has a substantial privacy interest that outweighs the presumption of openness in judicial proceedings. Id., citing, Doe v. 951 F.2d 320, 323 (11th Cir. 1992)(requiring complaint to include the names of the parties serves more than administrative convenience, it protects the public's legitimate interests in knowing all the facts involved, including the identity of the parties - thus denying request to proceed anonymously). The factors include:
+
+- a. whether the plaintiff is challenging governmental activity;
+- b. whether the party defending the suit would be prejudiced;
+- c. whether the plaintiff is required to disclose information of utmost intimacy;
+- d. whether the plaintiff is compelled to admit an intention to engage in illegal conduct, thereby risking criminal prosecution;
+- e. whether the Plaintiff would risk suffering injury if identified;
+
+- f. whether the interests of children are at stake; and
+- g. whether there are less drastic means of protecting the legitimate interests of either party.
+
+Doe 951 F.2d at 323.
+
+Plaintiff does not fall under any of the factors. Moreover, even if she did meet one of the factors, "[t]he fact that [a] Doe [Plaintiff] may suffer some personal embarrassment, standing alone, does not require the granting of a request to proceed under a pseudonym." Id; see also Doe v. Rostker 89 F.R.D. 159 (N.D. Calif. 1981). Any substantial privacy interests JANE DOE has must outweigh the customary and constitutionally embedded presumption of openness to judicial proceedings. Doe v. 951 F.2d at 323; Doe v. Berqstron 2009 WL 528623 (C.A.9(Or.))(denying request to proceed anonymously in civil action by Plaintiff where Plaintiffs arrest, prosecution and acquittal were matters of public record).
+
+14. In Sweetland v. State, 535 So.2d 646 (Fla. 1st DCA 1988), the court reasoned that the purpose of discovery is to eliminate the likelihood of surprise and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1)• see also Surf Drugs. Inc.. v. Vermette 236 So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), citing, Hickman v. Taylor 329 U.S. 495, 501, 507 (1947).
+
+15. Next, the right to go to court to resolve disputes is a fundamental right.
+
+D.R. Lakes, Inc. v. Brandsmart U.S.A. of West Palm Beach, 819 So.2d 971 (Fla. 4th
+
+DCA 2002). All litigants are afforded an equal opportunity. Lingle v. Dion 776 So.2d 1073 (Fla. 4th DCA 2001). The Florida Constitution establishes the right commonly known as access to courts. Mitchell v. Moore, 786 So.2d 521 (Fla. 2001). Courts shall be open to any person for the redress of any injury and justice shall be administered without sale, denial or delay. Art. I, §21, Fla. Const.; 10A Fla. Jur. 2d, Constitutional Law, §360.
+
+16. If Jane Doe's name is not disclosed and identified, Mr. Epstein will not be afforded his fundamental right to fairly litigate this dispute and prepare for trial. Accordingly, Epstein requests that JANE DOE be identified by her legal name in the pleadings.
+
+# c. Response In Opposition And Motion To Identify JANE DOE In Third-Party Subpoenas
+
+17. Epstein will be effectively denied his due process rights to conduct broad, open and liberal discovery in that Plaintiffs counsel has objected to, among other things, Epstein identifying JANE DOE in various third-party subpoenas to her medical providers and other third parties.
+
+18. The undersigned must serve subpoenas on medical doctors to obtain medical information on JANE DOE's alleged psychological and physical damages as same goes to the heart of Epstein's defenses and Plaintiffs damages. Plaintiff is claiming emotional/psychological damages. Therefore, Epstein is entitled to know her psychological condition(s) before and after the alleged incident(s) she references in the Complaint. In particular, JANE DOE alleges specific disorders as a result of Epstein's alleged conduct — suffer ". .physical injury, pain and suffering, emotional distress, psychological and
+
+psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy . . . , and medical and psychological expenses. . . , loss on income, loss of the capacity to earn income in the future, and loss of the capacity to enjoy life." (Emphasis Added). See supra. Epstein is also entitled to know, among other things, whether she had any physical complaints or whether there was ever any evidence of physical battery on JANE DOE's body from the acts she complains of in the Complaint. The need to serve third-party subpoenas on medical doctors is a basic discovery need related to the claims alleged by JANE DOE for which Plaintiffs counsel refuses to compromise. Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998)(discoverability of Plaintiffs history of sexual activity is relevant to damages); United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)(deals with "admissibility of other acts of sexual abuse by individuals other than the defendant to explain why a victim of abuse exhibited behavioral manifestations of a sexually abused child.") If Plaintiff saw a psychologist or other physician during or after the time periods she claims she was assaulted by Epstein but either did not discuss or did discuss the incidents (or lack thereof) would be directly relevant to her damage claims. Plaintiff seeks physical and emotional/mental personal injury type damages, and the Epstein must conduct his own discovery thereon. See supra. No valid discovery objections or exemptions exist preventing necessary and reasonable discovery. To hold otherwise prevents Mr. Epstein from preparing and defending this matter.
+
+19. In defending this lawsuit, Mr. Epstein should be permitted broad discovery, whether admissible at trial or not. Fed.R.Civ.Pro. 26 provides, in pertinent part, that "parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action."
+
+20. In addition, subpoenas must also be served upon various local and state institutions in order to determine what crimes, if any, JANE DOE has committed (i.e., crimes that involve dishonesty and/or false statement). Obviously, this goes directly to the heart of JANE DOE's damages she claims suffer ". . .physical injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy . . . , and medical and psychological expenses. . , loss on income, loss of the capacity to earn income in the future, and loss of the capacity to enjoy life" — caused by Epstein or other events in her life) for which a jury is entitled to hear about at trial, and certified records must be obtained from the clerk should JANE DOE answer certain questions regarding her crimes incorrectly.
+
+21. Epstein is entitled to know whether Jane Doe committed and/or was charged with any crimes. If Jane Doe was charged with crimes, Epstein is entitled to obtain certified copies of those crimes Plaintiff may have committed for purposes of discovery and impeachment. Questions will be asked regarding those crimes (e.g., Have you been convicted of a crime of dishonesty or false statement? If so, how many times? Have you been convicted of a felony? If so, how many times?) To hold otherwise would not only prevent broad discovery but would ultimately result in reversible error at any trial.
+
+## II. Conclusion and Prayer for Relief
+
+- 22. Epstein requests the following relief:
+  - a. That JANE DOE's Motion to Proceed Anonymously be denied;
+  - b. That this Court grant Epstein's Motion and that JANE DOE be identified by her legal name in the style of this case; and
+  - c. That Epstein be granted leave to identify JANE DOE by her legal name in Third-Party Subpoenas (but not file them in Court or, if required, in a redacted form).
+
+WHEREFORE, Epstein, Jeffrey Epstein, respectfully requests that this Court enter said order granting the relief requested above, and for such other and further relief as this Court may deem just and proper
+
+> By: / ROBERT R ON, JR., ESQ. MICHAEL J. PIKE, ESQ.
+
+### Certificate of Service
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this day of Mav, 2009
+
+Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 riosefsberqApodhurst.com kezellftpodhurst.com Counsel for Plaintiff
+
+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 jaqesa@bellsouth.net Counsel for Defendant Jeffrey Epstein
+
+Respectfully submitted,
+
+By:
+
+Florida Bar No. 224162
+
+[rcrit@bclclaw.com](mailto:rcrit@bclclaw.com)
+
+MICHAEL J. PIKE, ESQ.
+
+Florida Bar #617296
+
+[mpike@bclclaw.com](mailto: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)

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738227/EFTA02738227.md

@@ -0,0 +1,124 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2,
+
+
+
+
+
+JANE DOE NO. 3,
+
+
+
+
+
+CASE NO.: 08-CV-80119-MARRA
+
+CASE NO.: 08-CV-80232-MARRA
+
+/
+
+JANE DOE NO. 4,
+
+
+vs. JEFFREY EPSTEIN,
+
+
+JANE DOE NO. 5,
+
+
+
+
+CASE NO.: 08-CV-80380-MARRA
+
+CASE NO.: 08-CV-80381-MARRA/
+
+
+JANE DOE NO. 6,
+
+
+
+
+
+CASE NO.: 08-80994-CIV-MARRA/M.
+
+JANE DOE NO. 7, CASE NO.: 08-80993-CIV-MARRA
+
+
+
+
+
+C.M.A., CASE NO.: 08-8081 I -CIV-MARRA
+
+
+
+
+
+JANE DOE, CASE NO.: 08- 80893-CIV-MARRA/
+
+
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+DOE II, CASE NO.: 09- 80469-CIV-MARRA/=I.
+
+
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+JANE DOE NO. 101, CASE NO.: 09- 80591-CTV-MARRA
+
+
+
+
+
+JANE DOE NO. 102 CASE NO.: 09- 80656-CIV-MARRA
+
+
+
+
+
+## ORDER CONSOLIDATING CASES FOR PURPOSES OF DISCOVERY AND PROCEDURAL MOTIONS THAT RELATE TO MULTIPLE CASES
+
+THIS CAUSE is before the Court sua sponte. In the interests of judicial economy and
+
+efficiency, it is hereby ORDERED AND ADJUDGED as follows:
+
+I. The above-styled cases are hereby CONSOLIDATED for purposes of discovery and for procedural motions that relate to multiple cases.
+
+2. Hereinafter, all motions and other court filings that relate to discovery and all procedural motions that relate to multiple cases shall be styled with all of the case names and numbers, consistent with the styling of this Order, and shall be FILED ONLY IN Jane Doe No. 2 v. Epstein, case no. 08-80119, which is the lowest-numbered pending case. Any motions styled incorrectly or filed in multiple cases will be stricken from the docket for failure to follow the Court's Order.
+
+3. The parties may file separate motions to dismiss, answers to the complaint, summary judgment motions, motions in limine and other substantive motions that pertain to their individual cases and their individual trials under their individual case styles.
+
+4. Production of documents by any party or non-party that relate to multiple cases need be produced only once.
+
+5. Defendant is limited to a single deposition of each Plaintiff, during which Defendant may depose the Plaintiff as both a party and a witness.
+
+6. Defendant(s) may be deposed only once.
+
+7. Any other witnesses common to multiple cases may be deposed only once.
+
+8. For depositions, Local Rule 26.1 K (limiting deposition time to one day of seven hours) is waived so as to allow each party an adequate opportunity to develop fully the record as it may relate to that party. However, this waiver shall not be construed as authority for any party to take unnecessarily long depositions, or abuse the process. Any abuses of this waiver
+
+shall result in the imposition of appropriate sanctions against the offending party.
+
+**DONE AND ORDERED** in [REDACTED] at West Palm Beach, Palm Beach County,
+
+Florida, this 14{sup}`th` day of May, 2009
+
+
+
+---
+
+KENNETH A. MARRA  
+United States District Judge
+
+Copies furnished to:
+
+all counsel of record
+
+Magistrate Judge Linnea R. [REDACTED]

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738232/EFTA02738232.md

@@ -0,0 +1,435 @@
+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CV-80811-MARRAal
+
+C.M. A.,
+
+v.
+
+JEFFREY EPSTEIN and
+
+Plaintiff,
+
+Defendants,
+
+Defendant. Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedinps With Incorporated Memorandum Of Law
+
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing this action for atime certain (i.e., until late 2010 when the NPA expires), pursuant to the application of the Fifth Amendment of the U.S. Constitution and the fact that a parallel proceeding is ongoing and being investigated. In support of his motion, EPSTEIN states:
+
+### I. Introduction
+
+At the outset, EPSTEIN notes this Court's prior Order, dated December 16, 2008, (Document 28), in which this Court denied amotion for stay brought by Defendant's prior counsel. In that instance, Defendant's counsel requested a mandatory stay under 18 U.S.C.A. §3509(k) which the court denied. In denying the request for the stay, this Court stated that {sup}`a` discretionary stay was not appropriate at the time the order was entered but also stated, in part, that "Any such issues shall be resolved as they arise in the course of litigation.". As discussed herein, "special circumstances" now exist which, in the "interests of justice," merit the entry of {sup}`a` stay of this civil action until the criminal matter in the 15th Judicial Circuit is "closed" in
+
+accordance with the United States Attorney's Office ("USAO") Non-Prosecution Agreement ("NPA") and until the NPA expires.
+
+Moreover, EPSTEIN was indicted by a grand jury in or around July 2006. See Exhibit "A". The Non-Prosecution Agreement is part of the record in connection with that indictment, which is signed by the State Attorney of the 15th Judicial Circuit in and for Palm Beach County, Florida ("SAO"). In fact, the NPA acknowledges the investigation performed by the SAO. Further, the USAO was present at the Plea hearing whereby the NPA was made part of the record. Thus, there is no question that a parallel criminal matter exists in that the SAO's case remains open and the NPA lives along side it, which places EPSTEIN under grea{sup}`t`scrutiny by the USAO. The NPA actually places an affirmative duty upon EPSTEIN to undertake discussions with the SAO to ensure compliance with the NPA. That check and balance, therefore, remains in the hands of the SAO, which has a parallel criminal proceeding. Here, the threat of prosecution is real, substantial, and present should the USAO determine that EPSTEIN somehow violated the NPA. As discussed below, because the NPA fails to define what constitutes a breach, the USAO has apparently taken it upon itself to determine whether abreach has occurred and whether to seek criminal prosecution. In fact, the USAO has already attempted to claim violations of the NPA due to, among other things, EPSTEIN defending the civil actions against him. Clearly, it is NOT simply EPSTEIN's choice as to whether he violates the NPA — that discretion apparently lies with the USAO. For this reason alone, a stay is required until the NPA expires.
+
+The difference between this Motion and the prior motion to stay is solely due to the ripeness of the issues discussed herein.
+
+## H. THE NPA
+
+By its terms, the NPA took effect on June 30, 2008 and expires by those same terms in late 2010 so long as EPSTEIN complies with the terms and conditions — violations of which remain undefined. The NPA, which remains under seal, outlines various obligations on the part of EPSTEIN including, but not limited to, pleading guilty to the Indictment and Information before the 15th Judicial Circuit, recommendations for his sentencing before the 15th Judicial Circuit, waiver of challenges to the Information filed by the SAO, waiver of right to appeal his conviction, agreement not be afforded benefits for gain time, and the agreement to not prosecute others listed thereon so long as EPSTEIN does not breach and fulfills the requirements of the NPA.
+
+What the NPA does not outline or define is what constitutes a breach or what act or omission constitutes a breach thereof. Therefore, the USAO apparently believes it has the discretion to make that unwritten and undefined determination, which places an unreasonable burden upon EPSTEIN in defending the civil claims in that he has no idea what the USAO will define as a breach in the event he does not assert his 51° Amendment Rights. As an example, the USAO has already claimed that EPSTEIN violated the NPA by:
+
+- 1. investigating the Plaintiffs (by and though his attorneys) whom brought civil suits against him for purposes of defending those civil actions;
+  - 2. contesting damages in this action and in the other civil actions;
+- 3. making statements to the press about this Plaintiff or other Plaintiffs by and though his attorneys; and
+
+4. using the word "jail" instead of "imprisonment" in the plea agreement with SA's office.
+
+See Exhibit "B" Goldberger Affidavit - EPSTEIN's criminal counsel.
+
+These allegations are silly, unfounded and alleged violations which are not defined as violations under the NPA but arrived at by the USAO. Thus, EPSTEIN is left with "Morton's Fork" in his side - the undesirable choice of taking the 5th Amendment and having a judgment (summary or otherwise) entered against him in the civil action or the undesirable choice of subjecting himself to discovery in the civil action before the NPA expires and, thus, face the possibility of criminal prosecution by the USAO based upon some illusory breach deemed by the USAO by way of information obtained through civil discovery proceedings. This is inherently unfair, the danger is clear, and the playing field is not level in light of the NPA language or lack thereof.
+
+As a result, the threat of criminal prosecution against EPSTEIN by the USAO continues presently and through late 2010.
+
+### III, Justice Requires The Entry of A Stay Because Defendant Is Being Forced To Choose Between Waiving His 51h Amendment Privilege Or Risk Losing This Civil Case And Forfeiting Other Constitutional Guarantees Of Due Process And Effective Assistance Of Counsel
+
+Once the NPA expires, EPSTEIN fully intends to testify to all relevant and nonobjectionable inquiries made to him in discovery be it a deposition, in interrogatories or in production requests. (Emphasis Added) However, the current circumstances are such that by testifying or responding to discovery, EPSTEIN will be required to waive his constitutional privileges, thereby subjecting himself to criminal prosecution and scrutiny by the USAO as a
+
+Page 5
+
+result of matters alleged in this civil action (and others before this Court and in the State of Florida 15th Judicial Circuit Court, Palm Beach County).
+
+The special circumstances of this action are such that a stay or continuance for a time certain is NOT prejudicial and is required to be entered so that:
+
+(1) EPSTEIN is not required to waive his Fifth Amendment right against selfincrimination under the United States Constitution resulting in severe prejudice to EPSTEIN in pending criminal matters; and
+
+(2) EPSTEIN is not forced to choose between waiving his Fifth Amendment right against self-incrimination or losing the civil case.
+
+Here, in asserting his Fifth Amendment Privilege, the Plaintiff is afforded an opportunity rarely given - that is, to put on only her evidence without any counterevidence from Defendant resulting in ajudgment of liability against EPSTEIN. This is inherently unfair and precisely the special circumstances where "in the interests of justice" a stay is required. Ventura v. Brosky, {sup}`2006`WL 3392207 (S.D. Fla. 2006), citing United States v. Lot 5, Fox Grove, {sup}`23`F.3d 359 (11th Cir. 1994). In Ventura, {sup}`a`stay was entered where a Defendant was confronted with issue of waiving his 5th Amendment Privilege or to loose a civil case by way of motion for summary judgment. Id. Here, EPSTEIN is not requesting a mandatory stay. EPSTEIN only asks that this court recognize that "special circumstances" exists in this matter and enter a stay in the "interests of justice" and only for a specified period of time (i.e., after the NPA expires). See a\_122 Securities and Exchange Commission, {sup}`755`F.Supp. 1018, 1019 (S.D. Fla. 1990)(Defendant was in precarious position while being subject to criminal investigation and reasoning that compelling Defendant to speak by ordering an accounting of alleged illicit funds would directly
+
+Page 6
+
+impinge his right against self-incrimination). The court found it appropriate to grant the request for stay. (Emphasis Added).
+
+Citing to U.S. v. Lot 5, Fox Grove supra, the Southern District Court, Florida, in Ventura v. Brosky 2006 WL 3392207 (S.D. Fla. 2006), stated —
+
+The Eleventh Circuit has also created a test for these circumstances, stating that where there exists a concurrent civil and criminal proceeding, a court must stay a civil proceeding pending resolution of a related criminal prosecution when "special circumstances" so require in the "interests of justice."
+
+(Bold emphasis added). au also United States v. Kordel, 397 U.S. I, 12 & n. 27, 90 S.Ct. 763, 769-70 & n.27 (1970). The Ventura Court went on to state that "situations where a defendant in both criminal and civil proceedings must choose whether to waive his privilege against selfincrimination or to lose the civil case in summary or default judgment proceedings have met this test's burden and warrant a stay." Id. The Ventura court granted the stay. Here, the 15'h Judicial Circuit action lives along with the NPA.
+
+In making a decision to enter such a stay, the court may consider the following factors:
+
+- (I) the interests of the Plaintiffs in proceeding expeditiously with litigation, or any aspect of it, and the potential prejudice of Plaintiff to the delay;
+- (2) the burden which any particular aspect of the proceedings may impose on the defendant;
+- (3) the convenience of the court in the management of its cases, and the efficient use of judicial resources;
+  - (4) the interests of persons not parties to the civil litigation; and
+  - (5) the interest of the public in the pending civil and criminal litigation.
+
+Page 7
+
+See U.S. v. Pinnacle Ouest International, 2008 WL 4274498 (N.D. Fla. 2008).
+
+First, in applying the above factors, the Plaintiff in the instant matter will not be prejudiced simply by claiming a delay in time. Second, the burden is far greater on the EPSTEIN if he is forced to waive his 5th Amendment Privilege or remain silent and have a judgment entered against him or choose to testify and face criminal prosecution. Third, efficient use of judicial resources would be rendered upon a stay by way of preventing an appeal if such a stay is not entered. The Court has broad discretion to enter such a stay. Fourth, the interests of the individuals outlined in the NPA will be served because EPSTEIN's fulfillment of NPA alleged obligations is determinative upon whether the USAO prosecutes those individuals or whether the claims will be dropped upon the expiration of the NPA. Finally, the interest of the public in the pending civil and criminal cases will not be prejudiced as EPSTEIN is already serving his term whereby a plea was entered in the 15 Judicial Circuit action.
+
+## a. Application of the 5th Amendment
+
+Next, the Fifth Amendment privilege against self-incrimination "permits a person not to answer official questions put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), citinciting Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is also available to those who claim innocence. One of the Fifth Amendment's "basic functions ... is to protect innocent men ... 'who otherwise might be ensnared by ambiguous circumstances."); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process
+
+Clause of the Fourteenth Amendment - "(ilt would be incongruous to have different standards determine the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court."); Kastigar v. U.S., 406 U.S. 441, 444-45, 92 S.Ct. 1653 (1972XThe Fifth Amendment privilege "can be asserted in any proceeding, civil or criminal, administrative or judicial, investigatory or adjudicatory; and it protects against any disclosures which the witness reasonably believes could be used in a criminal prosecution or could lead to other evidence that might be so used. This Court has been zealous to safeguard the values which underlie the privilege." (Emphasis added)).
+
+The United States Supreme Court made it clear that the scope of the Fifth Amendment Privilege includes the circumstances as here "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see tAls2 Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Title 6, Chap. 13. The Privilege Against Self-Incrimination, §138 (6th Ed.). The privilege against self-incrimination may be asserted during discovery when a litigant has "reasonable grounds to believe that the response would furnish a link in the chain of evidence needed to prove a crime against a litigant." A witness, including a civil defendant, is entitled to invoke the Fifth Amendment privilege whenever there is a realistic possibility that the answer to a question could be used in anyway to convict the witness of a crime or could aid in the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company v. Conbov, 495 U.S. 248, 103 S.Ct. 608 (1983).
+
+Certainly, if the USAO decides to prosecute EPSTEIN for an alleged violation of the NPA, it would undoubtedly be able to use information obtained during discovery against him or
+
+Page 9
+
+use that information to aid in the development of other evidence against him at a criminal trial. The USAO is already claiming violations of the NPA based upon EPSTEIN defending the civil actions and, at the same time, while EPSTEIN asserts the 5th Amendment. Imagine, because that is all we can do based on the lack of wording in the NPA, what violations the USAO will assert if EPSTEIN is forced to waive his 5th Amendment privilege to defend himself in this and the other civil actions.
+
+The Fifth Amendment provides, in relevant part, that "No person ... shall be compelled in any Criminal Case to be a witness against himself." Hoffman v. United States, 341 U.S. 479, 486, 71 S.Ct. 814 (1951), citing v. United States, 1944, 322 U.S. 487, 489, 64 S.Ct. 1082, 1083, 88 L.Ed. 1408." The Fifth Amendment's privilege against self-incrimination is "accorded liberal construction in favor of the right it was intended to secure." "The immediate and potential evils of compulsory self-disclosure transcend any difficulties that the exercise of the privilege may impose on society in the detection and prosecution of a crime." Id., at 490; and In re Financial Svcs. of Fla.. Inc., 259 B.R. 391, 399 (M.D. Fla. 2000). The privilege not only extends to answers that would in themselves support a conviction under a criminal statute but likewise embraces those which would furnish a link in the chain of evidence needed to prosecute the claimant for a crime. Id citing Blau v. United States 1950, 340 U.S. 159, 71 S.Ct. 223. The Fifth Amendment privilege against self-incrimination "permits a person not to answer official questions put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d at 669, citing Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). As EPSTEIN is here, "the claimant must be 'confronted by substantial and `real,' and not merely
+
+trifling or imaginary, hazards of incrimination."' See generally United States v. Apfelbatun, 445 U.S. 115, 128, 100 S.Ct. 948, 956, 63 L.Ed.2d 250 (1980)). See also, United States v. Neff, 615 F.2d 1235, 1239 (9th Cir.), cert. denied, 447 U.S. 925, 100 S.Ct. 3018, 65 L.Ed.2d 1117 (1980XInformation is protected by the privilege not only if it would support a criminal conviction, but even if "the responses would merely `provide a lead or clue' to evidence having a tendency to incriminate."). EPSTEIN falls under each of the above category of cases.
+
+The United States Supreme Court has made clear that the scope of the Fifth Amendment Privilege also encompasses the circumstance where "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976). In explaining the application of the privilege, the Supreme Court stated:
+
+We have held that "the act of production" itself may implicitly communicate "statements of fact." By "producing documents in compliance with a subpoena, the witness would admit that the papers existed, were in his possession or control, and were authentic." Moreover, as was true in this case, when the custodian of documents responds to a subpoena, he may be compelled to take the witness stand and answer questions designed to determine whether he has produced everything demanded by the subpoena. The answers to those questions, as well as the act of production itself, may certainly communicate information about the existence, custody, and authenticity of the documents. Whether the constitutional privilege protects the answers to such questions, or protects the act of production itself, is a question that is distinct from the question whether the unprotected contents of the documents themselves are incriminating.
+
+"The issue presented in those cases was whether the act of producing subpoenaed documents, not itself the making of a statement, might nonetheless have some protected testimonial aspects. The Court concluded that the act of production could constitute protected testimonial communication because it might entail implicit statements of fact: by producing documents in compliance with a subpoena, the witness would admit that the papers existed, were in his possession or control, and were authentic. United States v. Doe, 465 U.S., at 613, and n. 11, 104 S.Ct. 1237. Fisher, 425 U.S., at 409-410. 96 S.Ct. 1569; id., at 428, 432, 96 S.Ct. 1569
+
+> (concurring opinions). See Braswell v. United States. 1487 U.S.,1 at 104, 108 S.Ct. 2284; f id..I at 122, 108 S.Ct. 2284 (dissenting opinion). Thus, the Court made clear that the Fifth Amendment privilege against self-incrimination applies to acts that imply assertions of fact."... An examination of the Court's application of these principles in other cases indicates the Court's recognition that, in order to be testimonial, an accused's communication must itself, explicitly or implicitly, relate a factual assertion or disclose information. Only then is a person compelled to be a 'witness' against himself." Doe v. United States. 487 U.S., at 209-210, 108 S.Ct. 2341 (footnote omitted).
+
+> Finally, the phrase "in any criminal case" in the text of the Fifth Amendment might have been read to limit its coverage to compelled testimony that is used against the defendant in the trial itself. It has, however, long been settled that its protection encompasses compelled statements that lead to the discovery of incriminating evidence even though the statements themselves are not incriminating and are not introduced into evidence. Thus, a half century ago we held that a trial judge had erroneously rejected a defendant's claim of privilege on the ground that his answer to the pending question would not itself constitute evidence of the charged offense. As we explained:
+
+> "The privilege afforded not only extends to answers that would in themselves support a conviction under a federal criminal statute but likewise embraces those which would furnish a link in the chain of evidence needed to prosecute the claimant for a federal crime." Hoffman v. United States. 341 U.S. 479, 486, 71 S.Ct. 814, 95 L.Ed. 1118 (1951).
+
+> Compelled testimony that communicates information that may "lead to incriminating evidence" is privileged even if the information itself is not inculpatory. Doe v. United States. 487 U.S. 201. 208, n. 6, 108 S.Ct. 2341, 101 L.Ed.2d 184 (1988). It's the Fifth Amendment's protection against the prosecutor's use of incriminating information derived directly or indirectly from the compelled testimony of the respondent that is of primary relevance in this case.
+
+The privilege against self-incrimination may be asserted during discovery when a litigant has "reasonable grounds to believe that the response would furnish a link in the chain of evidence needed to prove a crime against a litigant." A witness, including a civil defendant, is entitled to invoke the Fifth Amendment privilege whenever there is a realistic possibility that the answer to a question could be used in anyway to convict the witness of a crime or could aid in
+
+the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company v. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983). See also, Hubbell supra, as to what is encompassed by the phrase "in any criminal case" contained in the Fifth Amendment.
+
+As noted, the Fifth Amendment privilege against self-incrimination is broad. Hoffman; In re Financial Svcs., supra. To deny a witness the right to invoke the privilege, the judge must be perfectly clear, from a careful consideration of all the circumstances in the case, that the witness is mistaken, and that the answers cannot possibly have such tendency to incriminate. Id at 488, 399. Recognizing the breadth and magnitude of this constitutional privilege, the United States Supreme Court in discussing how a court is to analyze the application of the privilege stated —
+
+... It is for the court to say whether his silence is justified, Rogers v. United States, 1951, 340 U.S. 367, 71 S.Ct. 438, and to require him to answer if 'it clearly appears to the court that he is mistaken.' Temple v. Commonwealth 1880, 75 Va. 892, 899. However, if the witness, upon interposing his claim, were required to prove the hazard in the sense in which a claim is usually required to be established in court, he would be compelled to surrender the very protection which the privilege is designed to guarantee. To sustain the privilege, it need only be evident from the implications of the question, in the setting in which it is asked, that a responsive answer to the question or an explanation of why it cannot be answered might be dangerous because injurious disclosure could result. The trial judge in appraising the claim 'must be governed as much by his personal perception of the peculiarities of the case as by the facts actually in evidence.'
+
+Hoffman, supra at 486-487.
+
+Hoffman and its progeny establish that "in view of the liberal construction of the provision [protecting against self-incrimination], after a witness has asserted the privilege, he should be compelled to provide the requested information only if it "clearly appears" to the court
+
+Page 13
+
+that the witness was mistaken in his invocation of the privilege." (Emphasis added). In re MI Financial Svcs.,supra at 399, .gr Hoffman, at 486.
+
+In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable cause to apprehend danger from a direct answer." The risk of incrimination resulting from being subject to discovery or to testify in his own defense while the NPA exists is "substantial and real" and "not trifling or imaginary haphazards of communication." See generally, In re Financial Svcs., supra at 400. Based on the nature of Plaintiff's claims, along with the ongoing scrutiny of the USAO in the criminal matters, EPSTEIN has "reasonable grounds to believe that his responses to the discovery would furnish a link in the chain of evidence needed to prove a crime against him. Finally, in order to preserve the privilege, the privilege must be asserted or one risks the loss or waiver of this liberty ensuring protection. See generally, U.S. v.M, 846 F.2d 678, 690 (11th Cir. 1988)("First, it ignores the settled principle which requires a witness to assert his Fifth Amendment rights. A witness who testifies at any proceeding, instead of asserting his Fifth Amendment rights, loses the privilege. ... A civil deponent cannot choose to answer questions with the expectation of later asserting the Fifth Amendment.").
+
+Also applicable in upholding the assertion of the Fifth Amendment privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution. See Yarborough v. Gentry 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003)(Sixth Amendment guarantees criminal defendants effective assistance of counsel.), on remand 381 F.3d 1219. The United States Constitutional guarantees are applicable to the states through the Fourteenth Amendment. Obviously, EPSTEIN's assertion of his constitutional privileges and protections is on the advice of counsel. Again, EPSTEIN continues to face criminal prosecution by the USAO
+
+until the expiration of the NPA; under the constitutional guarantee of effective assistance of counsel, he is entitled to follow the recommended advice of his criminal defense attorney. See Goldberger Affidavit attached hereto.
+
+EPSTEIN's invocation of his constitutional protections of the Fifth, Sixth and Fourteenth Amendments must be upheld for the reasons set forth herein; otherwise such constitutional protections would be rendered meaningless. Already and recently, Defendant EPSTEIN in his Response and Objections to discovery, attached hereto as Exhibit "C", has been required to assert, on advice of counsel, his Fifth Amendment privilege against self-incrimination, along with his constitutional rights afforded under the Sixth and Fourteenth Amendments of the United States Constitution. Thus, EPSTEIN's entitlement to a stay is ripe for determination.
+
+Based upon the foregoing, a stay is warranted in this action as the Defendant is being forced to choose between the assertion of his Fifth Amendment right or losing this case by judgment (summary or otherwise) or waiver of his 5ih Amendment right and face potential criminal prosecution.
+
+By: ROBERT D. C Florida Bar No. 24162 rcrit@bciclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 ., ESQ.
+
+### Certificate of Service
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+
+day on all counsel of record identified on the following Service List in the manner specified by
+
+CM/ECF on this 24{sup}`th` day of March, 2009
+
+Richard Horace Willits, Esq.  
+Richard H. Willits, P.A.  
+2290 10{sup}`th` Avenue North  
+Suite 404  
+Lake Worth, FL 33461  
+561-582-7600  
+Fax: 561-588-8819  
+*Counsel for Plaintiff C.M.A.*  
+reelrhw@hotmail.com
+
+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 Epstein*
+
+Jack Scarola, Esq.  
+Jack P. [REDACTED], Esq.  
+Searcy Denney Scarola Barnhart & Shipley,  
+P.A.  
+2139 Palm Beach Lakes Boulevard  
+West Palm Beach, FL 33409  
+561-686-6300  
+Fax: 561-383-9424  
+jsx@searcylaw.com  
+jph@searcylaw.com  
+*Co-Counsel for Plaintiff*
+
+Bruce Reinhart, Esq.  
+Bruce E. Reinhart, P.A.  
+250 S. Australian Avenue  
+Suite 1400  
+561-202-6360  
+Fax: 561-828-0983  
+ecf@brucereinhartlaw.com  
+*Counsel for Defendant* [REDACTED]
+
+Respectfully submitted,
+
+By:
+
+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  
+561/842-2820 Phone  
+561/515-3148 Fax
+
+(Counsel for Defendant, Jeffrey Epstein)
+
+A TRUE BILL
+
+06-9454-CF  
+A2
+
+IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA
+
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL  
+CIRCUIT OF THE STATE OF FLORIDA
+
+For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two Thousand and Six, to-wit:  
+The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their  
+oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State  
+aforesaid,
+
+### COUNT ONE FELONY SOLICITATION OF PROSTITUTION
+
+on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31,  
+2005, did solicit, induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to  
+Florida Statute 796.07(1) on three or more occasions between August 01, 2004 and October 31, 2005,  
+contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1)
+
+against the form of the statute, to the evil example of all others, and against the peace and dignity of the State  
+of Florida.
+
+I hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law.
+
+*[Handwritten signature]*  
+Assistant State Attorney of the  
+Fifteenth Judicial Circuit of the State  
+of Florida, prosecuting for the said  
+State
+
+*[Handwritten signature]*  
+GRAND JURY FOREPERSON  
+DATE
+
+Jeffrey E. Epstein, Race: [Redacted], Sex: Male, DOB: January 20, 1953, SS#: 090-44-3348; Issue Warrant
+
+
+
+# AFFIDAVIT OF JACK A. GOLDBERGER, ESQUIRE
+
+STATE OF FLORIDA ) SS COUNTY OF PALM BEACH )
+
+BEFORE ME, the undersigned authority, personally appeared having personal knowledge and being duly sworn, deposes and says:
+
+1. I, Jack A. Goldberger, have personal knowledge of the matters set forth herein. I am an attorney licensed to practice in the State of Florida since 1978. I am a partner with the law firm of Atterbury Goldberger & Weiss, P.A., located at One Clearlake Centre, Suite 1400, 250 Australian Avenue South, West Palm Beach, FL 33401.
+
+2. My practice includes and specializes in the defense of criminal matters. I am board certified in criminal law. I have been and currently am the criminal defense attorney for JEFFREY EPSTEIN.
+
+3. I represented Mr. EPSTEIN in the negotiation of and entering into a Non-Prosecution Agreement with the United States Attorney's Office (USAO) for the Federal Southern District of Florida. The terms and conditions of the Non-Prosecution Agreement also entailed the entering of a Plea Agreement with the State Attorney's Office, Palm Beach County, State of Florida. (The Non-Prosecution Agreement shall hereinafter be referred to as the "NPA").
+
+4. By its terms, the NPA took effect on June 30, 2008. Also, pursuant to the terms of the NPA, any criminal prosecution against EPSTEIN is deferred as long as the terms and conditions of the NPA are fulfilled by EPSTEIN.
+
+
+
+5. The criminal matters against EPSTEIN remain ongoing until the NPA expires by its terms in late 2010, and as long as the USAO determines EPSTEIN has complied with those terms and conditions. The threat of criminal prosecution against EPSTEIN by USAO in the Southern District of Florida continues presently and through late 2010.
+
+6. Pursuant to the terms of the NPA, the USAO possesses the right to declare that the agreement has been breached, give EPSTEIN's counsel notice, and attempt to move forward with a prosecution. As of the date of this Affidavit, the USAO has taken the position on a number of occasions that it might consider the following actions by EPSTEIN to be a breach of the NPA.
+
+- Investigation by EPSTEIN (by and through his attorneys) of this Plaintiff and the other Plaintiffs in other pending civil cases for purposes of defending the civil actions;
+- EPSTEIN's contesting damages in this action and other civil actions.
+- EPSTEIN or his legal representatives making statements to the press about this Plaintiff or the other Plaintiffs.
+- Using the word "jail" instead of "imprisonment" in the plea agreement with the Palm Beach County State Attorney's Office.
+
+7. EPSTEIN, through counsel, submitted a Freedom of Information Act request to the Federal Bureau of Investigation (FBI) for documents relating to this and the other cases: the FBI denied the request stating the materials are at this time exempt from disclosure because they are in an investigative file, i.e. the matter is still an ongoing criminal investigation.
+
+8. The NPA expires in late 2010.
+
+FURTHER THE AFFIANT SAYETH NAUGHT
+
+STATE OF FLORIDA  
+COUNTY OF PALM BEACH
+
+I hereby Certify that on this day, before me, an officer duly authorized to administer oaths and take acknowledgments, personally appeared Jack A. Goldberger, Esquire, known to me to be the person described in and who executed the foregoing Affidavit, who acknowledged before me that he/she executed the same, that I relied upon the following form of identification of the above named person: Known Personally, and that an oath was/was not taken.
+
+WITNESS my hand and official seal in the County and State last aforesaid this 19{sup}`th` day of February, 2009.
+
+(SEARCHED
+
+![](_page_18_Picture_19.jpeg)
+
+*only  
+pley*
+
+**UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF FLORIDA**
+
+CASE NO.: 08-CV-80811-MARRA/ [REDACTED]
+
+C.M. A.,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN and [REDACTED]  
+[REDACTED]
+
+Defendants,
+
+\_\_\_\_\_/
+
+**DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS  
+TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION**
+
+![](_page_19_Picture_28.jpeg)
+
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, hereby responds to Plaintiff's First Request For Production To Defendant, served January 8, 2009 and states:
+
+**Request No. 1:** Any and all evidence required to be maintained by Epstein and the United States Attorney for the Southern District of Florida, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued in connection with the investigation referenced in the Non-Prosecution Agreement, and including certain computer equipment.
+
+**Response:** Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this
+
+**EXHIBIT "C"**
+
+*rp: JE, J6, DT  
+n. court*
+
+lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further, the request may include information subject to work product or an attorney-client privilege.
+
+Request No. 2: Any and all documents reflecting or relating to the identity of, the scheduling of, and/or the payment of any female compensated by or on behalf of Epstein for providing any service to Epstein that required, contemplated, or included in the provisions of such service, any physical contact between Epstein and the female, any act or prostitution, any illicit sexual conduct, the exposure of breast, buttocks or genitalia, or any commercial sex act as defined in 18 U.S.C. §1591(c)(1).
+
+Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the
+
+Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further Defendants objects to the production as overly broad and seeking information that is neither relevant to the subject matter of the pending action nor does it appear to be reasonably calculated to lead to the discovery of admissible evidence. The Plaintiff in this instance has alleged in her complaint that she was sexually abused by the Defendant on one occasion sometime in the year 2004. The documents requested herein have no time period provided, and therefore the information sought is grossly overbroad.
+
+Request No. 3: Any and all documents reflecting or relating to the identity of and/or the nature and extent of any other person's participation in the communication with and/or the scheduling of and/or the payment of any person who participated in any conduct described in Request #2.
+
+Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this
+
+lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further Defendants objects to the production as overly broad and seeking information that is neither relevant to the subject matter of the pending action nor does it appear to be reasonably calculated to lead to the discovery of admissible evidence. The Plaintiff in this instance has alleged in her complaint that she was sexually abused by the Defendant on one occasion sometime in the year 2004. The documents requested herein have no time period provided, and therefore the information sought is grossly overbroad.
+
+## Certificate of Service
+
+I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S. mail to the following addressees, on this 6th day of February , 2009
+
+Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600
+
+Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300
+
+Page 5
+
+Fax: 561-588-8819
+
+Counsel for Plaintiff C.M.A.
+
+reelrhwehotmail.com
+
+Jack Scarola, Esq.
+
+Jack P. El Esq.
+
+Searcy Denney Scarola Bamhart Shipley, P.A.
+
+2139 Palm Beach Lakes Boulevard
+
+West Palm Beach, FL 33409
+
+561-686-6300
+
+Fax: 561-383-9424
+
+isxO.searcylaw.com
+
+jph searcylaw.com
+
+Co-Counsel for Plaintiff
+
+Fax: 561-835-8691
+
+jaaesqe.bellsouth.net
+
+Counsel for Defendants Jeffrey Epstein and
+
+Bruce Reinhart, Esq.
+
+Bruce E. Reinhart, P.A.
+
+& 250 S. Australian Avenue
+
+Suite 1400
+
+
+561-202-6360
+
+Fax: 561-828-0983
+
+ecfebrucereinhartlaw.com
+
+Counsel for Defendant
+
+Respectfully sub
+
+By:
+
+ROBERT D. RITTON, JR., ESQ.
+
+Florida Bar o. 224162
+
+rcritabcIclaw.com
+
+MICHAEL J. PIKE, ESQ.
+
+Florida Bar #617296
+
+moike(d)bcIclaw.com
+
+BURMAN, CRITTON, LUTTIER & COLEMAN
+
+515 N. Flagler Drive, Suite 400
+
+
+561/842-2820 Phone
+
+561/515-3148 Fax
+
+(Counsel for Defendant Jeffrey Epstein)

marker2-fixhub/court-doe-101-v-epstein/EFTA02738232/EFTA02738232.receipt.json

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738256/EFTA02738256.md

@@ -0,0 +1,101 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2,
+
+
+
+
+
+JANE DOE NO. 3,
+
+
+
+
+
+CASE NO.: 08-CV-80119-MARRA
+
+CASE NO.: 013-CV-80232-MARRA
+
+/
+
+JANE DOE NO. 4,
+
+
+vs. JEFFREY EPSTEIN,
+
+
+JANE DOE NO. 5,
+
+
+
+
+CASE NO.: 08-CV-80380-MARRA
+
+CASE NO.: 08-CV-80381-MARRA/
+
+
+JANE DOE NO. 6,
+
+
+
+
+
+JANE DOE NO. 7,
+
+
+
+
+
+CASE NO.: 08-80994-CIV-MARRA
+
+CASE NO.: 08-80993-CIV-MARRA
+
+C.M.A., CASE NO.: 08-8081 I-CIV-MARRA
+
+
+
+
+
+JANE DOE, CASE NO.: 08- 80893-CIV-MARRA/
+
+
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+DOE II, CASE NO.: 09- 80469-CIV-MARRA/
+
+
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+JANE DOE NO. 101, CASE NO.: 09- 80591-CIV-MARRA
+
+
+
+
+
+/
+
+JANE DOE NO. 102 CASE NO.: 09- 80656-CIV-MARRA
+
+
+
+
+
+## ORDER REQUESTING THE UNITED STATES TO PROVIDE ITS POSITION REGARDING DEFENDANT EPSTEIN'S MOTION TO STAY/CONTINUE THE CIVIL CASES PENDING AGAINST HIM
+
+THIS CAUSE is before the Court upon the motions filed in several cases by Defendant
+
+Jeffrey Epstein to Stay and/or Continue the Action for Time Certain Based on Parallel Civil and Criminal Proceedings. See, e.g., docket entry 51 in C.M.A. v. Epstein and =, case no. 08- 80811 (attached). Epstein moves for a stay until the expiration of the Non-Prosecution Agreement ("NPA") with the United States Attorney's Office (USAO) because, he claims, the USAO has taken the position that he is violating the NPA by defending the civil actions filed against him. Therefore, he argues that he cannot defend the civil actions without subjecting himself to criminal prosecution.
+
+While the Court recognizes that the United States is not a party to these actions and is not obligated to comment on this matter, the position of the United States would greatly assist the Court in resolving the merits of these motions to continue/stay the case. Accordingly, the Court requests that the United States provide its position on the matter. The Court would appreciate the governments position within 15 days if possible. If the United States is unwilling to state its position, the Court would also appreciate being so advised.
+
+DONE AND ORDERED in at West Palm Beach, Palm Beach County, Florida, this 141h day of May, 2009
+
+> KENNETH A. MARRA United States District Judge
+
+Copies furnished to: all counsel of record Ann Villafana

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738260/EFTA02738260.md

@@ -0,0 +1,66 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 09-CIV- 80591 - KAM
+
+JANE DOE NO. 101,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## DEFENDANT EPSTEIN'S UNOPPOSED MOTION TO EXCEED PAGE LIMITATION FOR DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT
+
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, moves to exceed the page limitation of 20 pages imposed by Loc. Gen. Rule 7.1. C. 2. (S.D. Fla.), in his memorandum of law in support of his motion to dismiss directed to Plaintiff JANE DOE No. 101's First Amended Complaint [DE 9), dated May 1, 2009. In support of his motion, Defendant states:
+
+1. Local Gen. Rule 7.1 C. 2. provides in part that absent prior permission of the court, no party shall file any legal memorandum exceeding 20 pages in length. Defendant is in the process of preparing his motion to dismiss and alternative motion for more definite statement, and his supporting memorandum of law directed to Plaintiffs First Amended Complaint. (Defendant's response to the First Amended Compalint is due May 26, 2009). The legal memorandum will exceed the 20 page limitation. It is clear based on the issues raised in Plaintiffs complaint that in excess of 20 pages is required to fully and adequately discuss the issues raised in moving to dismiss Plaintiffs action.
+
+Jane Doe II v. Epstein, et al. Page 2
+
+2. The issues being addressed pertain to the interpretation and application of 18 U.S.C. §2255. Some of these issues include but are not limited to constitutional law issues and what version of 18 U.S.C.A. §2255 applies to this action, and the meaning of §2255 with respect to the cause of action created and the presumptive minimum damages amount imposed. (It is Defendant's position that the 2006 amended version does NOT apply to this action; rather, it is the statute in effect during the time of the alleged conduct that apply).
+
+3. A length exceeding 20 pages is required so that Defendant may fully address the issues raised in Plaintiffs First Amended Complaint and in seeking dismissal thereof. Under the constitutional guarantees of due process, including a fair and full opportunity to be heard, and in the interests of justice so that the Court may render a fully informed decision on the issues, Defendant is entitled to an order granting his motion to exceed the page limitation. (Defendant anticipates that the legal memorandum will be approximately 30-35 pages in length.)
+
+4. As certified below, Plaintiff's counsel agreed to the request to exceed 20 pages.
+
+WHEREFORE, Defendant respectfully requests that this Court grant Defendant's motion, and enter an order allowing Defendant's legal memorandum in support of dismissal of Plaintiffs action to be in excess of 20 pages.
+
+## Rule 7.1 Certification
+
+Pursuant to communication by telephone, Plain ff s counsel has no objection to the request to exceed 20 pages herein.
+
+Counsel fo t EPSTEIN
+
+Jane Doe II v. Epstein, et al.  
+Page 3
+
+### Certificate of Service
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 16th day of May, 2009
+
+Robert C. Josefsberg, Esq.  
+Katherine W. Ezell, Esq.  
+Podhurst Orseck, P.A.  
+25 West Flagler Street, Suite 800  
+Miami, FL 33130  
+305 358-2800  
+Fax: 305 358-2382  
+[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com)  
+[kezell@podhurst.com](mailto:kezell@podhurst.com)  
+*Counsel for Plaintiff*
+
+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](mailto:jagesq@bellsouth.net)  
+*Counsel for Defendant Jeffrey Epstein*
+
+Respectfully submitted,
+

marker2-fixhub/court-doe-101-v-epstein/EFTA02738260/EFTA02738260.receipt.json

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738263/EFTA02738263.md

@@ -0,0 +1,163 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2
+
+
+
+
+JANE DOE NO. 3
+
+
+
+
+JANE DOE NO. 4
+
+
+
+
+JANE DOE NO. 5
+
+
+
+
+CASE NO.: 08-CV-80119-MARRA
+
+CASE NO.: 08-CV-80232-MARRA
+
+CASE NO.: 08-CV-80380-MARRA I
+
+CASE NO.: 08-CV-80381-MARRA
+
+JANE DOE NO. 6
+
+
+
+
+JANE DOE NO. 7
+
+
+
+
+C.M.A.
+
+
+
+
+JANE DOE
+
+
+
+
+CASE NO.: 08-CV-80994-MARRA
+
+CASE NO.: 08-CV-80993-MARRA/
+
+CASE NO.: 08-CV-80811-MARRA/
+
+CASE NO.: 08-CV-80893-MARRA
+
+DOE II
+
+
+
+
+
+JANE DOE NO. 101
+
+
+
+
+
+JANE DOE NO. 102
+
+
+
+
+
+CASE NO.: 09-CV-80469-MARRA/M=
+
+CASE NO.: 09-CV-80591-MARRA/
+
+CASE NO.: 09-CV-80656-MARRA/
+
+PLAINTIFF'S NOTICE OF FILING WITHDRAWAL OF PREVIOUSLY RAISED OBJECTIONS TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO COMPEL AND/OR IDENTIFY C.M.A. IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY C.M.A. IN THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY, OR, ALTERNATIVELY, MOTION TO DISMISS SUA SPONTE, WITH INCORPORATED MEMORANDUM OF LAW
+
+Plaintiff, C.M.A., by and through her undersigned attorneys, hereby files notice of withdrawal of previously raised objections to Defendant, JEFRREY EPSTEIN'S, Motion
+
+to Compel and/or Identify C.M.A. in the Style of This Case and Motion to Identify C.M.A. in Third-Party Subpoenas For Purposes of Discovery, or; Alternatively, Motion to Dismiss Sua Sponte, With Incorporated Memorandum of Law, and further states as follows:
+
+1. Defendant, JEFFREY EPSTEIN, filed a Motion to Compel and/or Identify C.M.A. in the Style of This Case and Motion to Identify C.M.A. in Third-Party Subpoenas For Purposes of Discovery, or, Alternatively, Motion to Dismiss Sua Sponte, With Incorporated Memorandum of Law (D.E. 67) on April 29, 2009.
+
+2. EPSTEIN's Motion seeks the following relief (taken verbatim from the conclusion of his Motion):
+
+- a) "That C.M.A. be identified by her legal name in the style of this case;
+- b) That Epstein be granted leave to identify C.M.A. by her legal name in Third-Party Subpoenas (but not file them in Court, or, if required, in a redacted form); and
+- c) That on an alternative basis, this court dismiss this action Sua Sponte until such time as C.M.A. identifies herself in the style of this matter.
+
+Doe v. Rostker 89 F.R.D at 163."
+
+3. Plaintiff withdraws her objection to a) and b) requested above. The request to have C.M.A.'s case dismissed is rendered moot given C.M.A.'s acquiescence to a) and b). To the extent that it is not, however, C.M.A. continues to object to c) above.
+
+4. Counsel for EPSTEIN is free to prepare a proposed agreed order reflecting the above for the Court's consideration following the undersigned's review of same.
+
+## CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
+
+Counsel for the movant conferred via telephone with counsel for the Defendant regarding the filing of the instance Notice and he has no objection to Plaintiff filing same.
+
+s/ Jack P.
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that on the 20th day of May, 2009, I electronically filed the foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice of electronic filing to all counsel of record on the attached service list.
+
+> /c/.lack P ■ **Jack Scarola Florida Bar No.: 169440 Jack P. Florida ar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9424 Attorneys for Plaintiff, C.M.A.**
+
+**COUNSEL LIST**
+
+Richard H. Willits, Esquire
+
+Richard H. Willits, P.A.
+
+2290 10th Avenue North, Suite 404
+
+Lake Worth, FL 33461
+
+Phone: (561) 582-7600
+
+Fax: (561) 588-8819
+
+Robert Critton, Esquire
+
+Burman Critton Luttier & Coleman LLP
+
+515 North Flagler Drive, Suite 400
+
+West Palm Beach, FL 33414
+
+Phone: (561) 842-2820
+
+Fax: (561) 844-6929
+
+Jack A. Goldberger, Esquire
+
+Atterbury, Goldberger & Weiss, P.A.
+
+250 Australian Avenue South
+
+West Palm Beach, FL 33401
+
+Phone: (561) 863-9100
+
+Bruce E. Reinhart, Esquire
+
+Bruce E. Reinhart, P.A.
+
+250 South Australian Avenue
+
+Suite 1400
+
+West Palm Beach, FL 33401
+
+Phone: (561) 202-6360
+
+Fax: (561) 828-0983

marker2-fixhub/court-doe-101-v-epstein/EFTA02738263/EFTA02738263.receipt.json

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738269/EFTA02738269.md

@@ -0,0 +1,31 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 9:09-CV-80591-KAM
+
+Jane Doe 101,
+
+Plaintiff,
+
+vs.
+
+Jeffrey Epstein,
+
+Defendant.
+
+## CERTIFICATION OF JAY P. LEFKOWITZ
+
+Jay P. Lefkowitz, P.C., 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 bars of the State of New York and District of Columbia, and am admitted to practice before the United States Supreme Court, the United States Courts of Appeals for the District of Columbia Circuit, Second Circuit, Fourth Circuit, Fifth Circuit, Eighth Circuit, Ninth Circuit, and Eleventh Circuit, the United States District Courts for the District of Columbia, Southern District of New York, Pastern District of Michigan, Eastern District of Wisconsin, and District of Colorado, and the United States Tax Court.
+
+> {sup}`4`Cts-Lts P•( • [ Jay flcowitz, P.C. 11.4.5
+
+## 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 electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this day of May, 2009
+
+Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsberget>odhurstcom kezell®podhurst.com Counsel for Plaintiff
+
+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 iaaesoRbellsouth.net Counsel for Defendant Jeffrey Epstein
+
+Respectfully subm
+
+By: ROBERT D. TTON, JR., ESQ. Florida Bar 224162 rcrit@bciclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpike@bc1claw.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 jar Defendant Jeffrey Epstein)

marker2-fixhub/court-doe-101-v-epstein/EFTA02738269/EFTA02738269.receipt.json

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738271/EFTA02738271.md

@@ -0,0 +1,27 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 9:09-CV-80591-KAM
+
+Jane Doe 101,
+
+Plaintiff,
+
+vs.
+
+Jeffrey Epstein,
+
+Defendant.
+
+## ORDER GRANTING MOTION FOR LIMITED APPEARANCE OF JAY P. LEFKOWITZ, P.C., CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILINGS
+
+THIS CAUSE having come before the Court on the Motion for Limited Appearance of Jay P. Lefkowitz, P.C. and Consent to Designation, requesting, pursuant to Rule 4B of the Special Rules Governing the Admission and Practice of Attorneys in the United States District Court for the Southern District of Florida, permission for a limited appearance of Jay P. Lefkowitz, P.C. in this matter and request to electronically receive notice of electronic filings. This Court having considered the motion and all other relevant factors, it is hereby
+
+ORDERED and ADJUDGED that:
+
+The Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings is GRANTED. Jay P. Lefkowitz, P.C. is granted to appear and participate in this action on behalf of Jeffrey Epstein. The Clerk shall provide electronic notification of all electronic filings to Jay P. Lefkowitz, P.C. at jay.lefkowitz@lcirkland.com.
+
+Case No. 9:09-CV-80591-ICAM
+
+DONE AND ORDERED in day of at , Florida this
+
+Copies furnished to: All Counsel of Record United States District Judge

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738273/EFTA02738273.md

@@ -0,0 +1,41 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 9:09-CV-80591-KAM
+
+Jane Doe 101,
+
+Plaintiff,
+
+vs.
+
+Jeffrey Epstein,
+
+Defendant.
+
+## MOTION FOR LIMITED APPEARANCE, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILINGS
+
+In accordance with Local Rule 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 Jay P. Lefkowitz, P.C., of the law firm of Kirkland & Ellis LLP (Citigroup Center, 153 East 53rd Street, New York, New York 10022- 4611, Telephone: 212-446-4970), for purposes of limited appearance as co-counsel on behalf of Defendant Jeffrey Epstein herein, in the above-styled case only, and pursuant to Rule 2B, Southern District of Florida, CWECF Administrative Procedures, to permit Jay P. Lefkowitz, P.C. to receive electronic filings in this case, and in support thereof states as follows:
+
+1. Jay P. Lefkowitz is not admitted to practice in the Southern District of Florida and is a member in good standing of the bars of the State of New York and District of Columbia, and is admitted to practice before the United States Supreme Court, the United States Courts of Appeals for the District of Columbia Circuit, Second Circuit, Fourth Circuit, Fifth Circuit, Eighth Circuit, Ninth Circuit, and Eleventh Circuit, the United States District Courts for the
+
+District of Columbia, Southern District of New York, Eastern District of Michigan, Eastern District of Wisconsin, and District of Colorado, and the United States Tax Court.
+
+2. Movant, Robed D. Critton, Jr., Esquire, of the law firm of Burman Critton Luther & Coleman, P.A. (515 N. Flagler Drive, Suite 400, West Palm Beach, FL 33401, Telephone: 561-842-2820), is a member in good standing of 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 is 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, 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, Jay P. Lefkowitz, P.C. has made payment of this Court's \$75 admission fee. A certification in accordance with Rule 4B is attached hereto.
+
+4. Jay P. Lefkowitz, P.C., 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 Jay P. Lefkowitz, P.C. at email address: jay.lefkowitz®kirkland.com.
+
+WHEREFORE, Robed D. Critton, Jr. moves this Court to enter an Order permitting Jay P. Lefkowitz, P.C. to appear before this Court on behalf of Jeffrey Epstein for all purposes relating to the proceedings in the above-styled matter and directing the Clerk to provide notice of electronic filings to Jay P. Lefkowitz, P.C.
+
+## 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 electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 2181 day of Mav, 2009
+
+Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsbergatiodhurst.com kezell@podhurst.com Counsel for Plaintiff'
+
+Respectfully submitted,
+
+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 jages(abellsouth.net Counsel for Defendant Jeffrey Epstein
+
+ROBERT 'D. CRITTON, JR., ESQ. Florida ar No. 224162 rcrit@bciclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpike@bcIclaw.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)

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738276/EFTA02738276.md

@@ -0,0 +1,49 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 9:09-CV-80591-KAM
+
+Jane Doe 101,
+
+Plaintiff,
+
+vs.
+
+Jeffrey Epstein,
+
+Defendant.
+
+I
+
+## CERTIFICATION OF MICHAEL D. SHUMSKY
+
+Michael D. Shumsky, Esquire, pursuant to Rule 4B of the Special Rules Governing the Admission and Practice of Attorneys, hereby certifies that (I) I have studied the Local Rules of the United States District Court for the Southern District of Florida; and (2)1 am a member in good standing of the bars of the State of Connecticut and District of Columbia, and am admitted to practice before the United States Supreme Court, the United States Courts of Appeals for the Second Circuit, Seventh Circuit, Ninth Circuit, District of Columbia Circuit, and Federal Circuit, and the United States District Court for the District of Columbia.
+
+Miclf5el IS. Shumsky
+
+**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 electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 21{sup}`st` day of May, 2009
+
+Robert C. Josefsberg, Esq.  
+Katherine W. Ezell, Esq.  
+Podhurst Orseck, P.A.  
+25 West Flagler Street, Suite 800  
+Miami, FL 33130  
+305 358-2800  
+Fax: 305 358-2382  
+[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com)  
+[kezell@podhurst.com](mailto:kezell@podhurst.com)  
+*Counsel for Plaintiff*
+
+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](mailto:jagesq@bellsouth.net)  
+*Counsel for Defendant Jeffrey Epstein*
+
+Respectfully submitted,
+

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738278/EFTA02738278.md

@@ -0,0 +1,27 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 9:09-CV-80591-KAM
+
+Jane Doe 101,
+
+Plaintiff,
+
+vs.
+
+Jeffrey Epstein,
+
+Defendant.
+
+## ORDER GRANTING MOTION FOR LIMITED APPEARANCE OF MICHAEL D. SHUMSICY, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILINGS
+
+THIS CAUSE having come before the Court on the Motion for Limited Appearance of Michael D. Shumsky and Consent to Designation, requesting, pursuant to Rule 4B of the Special Rules Governing the Admission and Practice of Attorneys in the United States District Court for the Southern District of Florida, permission for a limited appearance of Michael D. Shumsky in this matter and request to electronically receive notice of electronic filings. This Court having considered the motion and all other relevant factors, it is hereby
+
+ORDERED and ADJUDGED that:
+
+The Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings is GRANTED. Michael D. Shumsky is granted to appear and participate in this action on behalf of Jeffrey Epstein. The Clerk shall provide electronic notification of all electronic filings to Michael D. Shumsky at michael.shumsky®kirkland.com.
+
+Case No. 9:09-CV-80591-KAM
+
+DONE AND ORDERED in day of at , Florida this
+
+Copies furnished to: All Counsel of Rccord United States District Judge

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marker2-fixhub/court-doe-101-v-epstein/EFTA02738280/EFTA02738280.md

@@ -0,0 +1,39 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 9:09-CV-80591-KAM
+
+Jane Doe 101,
+
+Plaintiff,
+
+vs.
+
+Jeffrey Epstein,
+
+Defendant.
+
+## MOTION FOR LIMITED APPEARANCE, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILINGS
+
+In accordance with Local Rule 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 Michael D. Shumsky, of the law firm of Kirkland & Ellis LLP (655 15th Street N.W., Washington, D.C. 20005, Telephone: 202-879- 5228), for purposes of limited appearance as co-counsel on behalf of Defendant Jeffrey Epstein herein, in the above-styled case only, and pursuant to Rule 2B, Southern District of Florida, CMIECF Administrative Procedures, to permit Michael D. Shumsky to receive electronic filings in this case, and in support thereof states as follows:
+
+1. Michael D. Shumsky is not admitted to practice in the Southern District of Florida and is a member in good standing of the bars of the State of Connecticut and District of Columbia, and is admitted to practice before the United States Supreme Court, the United States Courts of Appeals for the Second Circuit, Seventh Circuit, Ninth Circuit, District of Columbia Circuit, and Federal Circuit, and the United States District Court for the District of Columbia.
+
+2. Movant, Robert D. Critton, Jr. Esquire, of the law firm of Burman Critton Luttier & Coleman, P.A. (515 N. Flagler Drive, Suite 400, West Palm Beach, FL 33401, Telephone: 561-842-2820), is a member in good standing of 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 is 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, 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, Michael D. Shumsky has made payment of this Court's \$75 admission fee. A certification in accordance with Rule 4B is attached hereto.
+
+4. Michael D. Shumsky, 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 Michael D. Shumsky at email address: michael.shumsky®Icirkland.com.
+
+WHEREFORE, Robert D. Critton, Jr. moves this Court to enter an Order permitting Michael D. Shumsky to appear before this Court on behalf of Jeffrey Epstein for all purposes relating to the proceedings in the above-styled matter and directing the Clerk to provide notice of electronic filings to Michael D. Shumsky.
+
+## 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 electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 21ft day of May, 2009
+
+Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsbergepodhurst.com kezell@podhurst.com Counsel for Plaintiff
+
+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 jagesdQbellsouth.net Counsel for Defendant Jeffrey Epstein
+
+Respectfully sub ed,
+
+ROBERT . CRITTON, JR., ESQ. Florida ar No. 224162 rcrit@bc1claw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpike(4bc1claw.com BURMAN, CRITTON, LUTHER & 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)

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