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+### IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE No. 102,
+
+Plaintiff,
+
+VS.
+
+JEFFREY EPSTEIN,
+
+09-80656
+
+Civil Action No.
+
+CIV-RYSKA MP
+
+MAGISTRATE JUDGE VITUNAC
+
+I FILED by 11:/3 D C INTAKE
+
+MAY - 12009
+
+STEVEN a 4ARIMORE Ca%U.S. OUST. CT
+
+COMPLAINT AND Defendant. DEMAND FOR JURY TRIAL
+
+### COMPLAINT AND DEMAND FOR JURY TRIAL
+
+Plaintiff, Jane Doe No. 102, brings this Complaint against Defendant, Jeffrey Epstein, and states as follows:
+
+#### PARTIES. JUFtISDICIION, AND VENUE
+
+- 1. At all times material to this cause of action, Plaintiff, Jane Doe No. 102, 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. 102, 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 over 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, spanning the ages of 45 and 55 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," a 70-acre private island known as Little St. James in St. , 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 to countless vulnerable and relatively economically disadvantaged minor girls, and 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 girls 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 minor girls 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 and/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 call economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered 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 12 years old, were transported to Defendant's Palm Beach 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 nude photographs and/or videos of the underage girls for Defendant with and/or without their knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of dollars.
+
+13. Epstein designed this scheme to secure a private place in Defendant's Palm Beach 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 Palm Beach 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 six homes and/or on his computers.
+
+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 exploitations took place varied and is not yet completely known; however, Defendant committed such acts regularly 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. 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 I 1 through the present paragraph occurred in all of Defendant's domestic and international residences and/or places of lodging and/or modes of transportation.
+
+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. A vulnerable young girl, Plaintiff was working as a changing room assistant at The Mar-A-Lago Club in Palm Beach making approximately S9 an hour when she was first lured into Defendant's sexually exploitative world. In or about the summer of 1998, when Plaintiff was merely fifteen years old while attending to her duties at Mar-A-Lago, Plaintiff was recruited by Ghislaine Maxwell, who lived, traveled, socialized, and worked with Defendant. Ms. Maxwell asked Plaintiff if she was interested in learning massage therapy and earning a great deal of money while learning the profession. Plaintiff's father, who was a maintenance manager at The Mar-A-
+
+Lago Club, was not apprehensive because he felt comforted that an older woman had approached Plaintiff with this opportunity. As a result, Plaintiffs father dropped off Plaintiff at Defendant's mansion that same day. Ms. Maxwell met Plaintiff and her father outside of Defendant's Palm Beach mansion, where Ms. Maxwell assured the minor girl's father that Ms. Maxwell would provide transportation home for his teenaged daughter. Ghislaine Maxwell led Plaintiff up a flight of stairs to a spa room with a shower and a massage table. Defendant was lying naked on the massage table. Plaintiff was shocked, but, with no experience with massages, thought this could be massage therapy protocol. Ms. Maxwell then took off her own shirt and left on her underwear and started rubbing her breasts across Defendant's body, impliedly showing Plaintiff what she was expected to do. Ms. Maxwell then told Plaintiff to take off her clothes. The minor girl was apprehensive about doing this, but, in fear, proceeded to follow Ms. Maxwell by removing everything but her underwear. She was then ordered to remove her underwear and to straddle Defendant. The encounter escalated, with Defendant and Ms. Maxwell sexually assaulting, battering, exploiting, and abusing Plaintiff in various ways and in various locations, including the steam room and shower. At the end of this sexually exploitive abuse, Defendant and Ms. Maxwell giddily told Plaintiff to return the following day and told her she had "lots of potential." Defendant paid Plaintiff hundreds of dollars, told her it was for two hours of work, and directed one of his employees to drive her home.
+
+18. Defendant and/or his procurers thereafter lured the then minor Plaintiff to his Palm Beach mansion every day for the next two weeks in order to engage in a similar pattern of sexual exploitation. Defendant and/or his procurers arranged at the end of each incident the transportation and scheduling for the following day's appointment. Additionally, Defendant telephoned the minor Plaintiff himself and/or had Ms. Maxwell telephone Plaintiff to make arrangements. Plaintiff was often times driven to and from Epstein's mansion by Epstein
+
+himself or his driver. Alternatively, Defendant or Ms. Maxwell would arrange and pay for Plaintiff's transportation home by taxicab.
+
+19. During Plaintiff's second incident of being sexually exploited and assaulted by Defendant at Defendant's Palm Beach mansion, Defendant asked Plaintiff to quit her job at The Mar-A-Lago Club and travel with him to earn much more money while ►earning **the massage profession. Thus, Plaintiff, an impressionable and vulnerable young girl of modest means, quit her job as a changing room assistant, was lured by Defendant, and continued to be victimized by Defendant, who immersed the minor Plaintiff into Defendant's lewd and abusive lifestyle. Under Defendant's dominion and control, Defendant continuously "groomed" the minor adolescent. Defendant's daily routine required the minor Plaintiff to perform sexually on Defendant multiple times per day and to provide Defendant massages multiple times per day. Plaintiff had absolutely no say as to when, how many times, or what was done during each sexual encounter. Often, Plaintiff was joined by Ms. Maxwell, Ms. Maxwell's assistant, and/or a countless array of young women who would be brought to one of Defendant's homes for the sexual trysts and then be sexually exploited by Defendant.** 
+
+**20. The first time that Defendant transported Plaintiff to another state in order to engage in sexual acts with her occurred when she was merely fifteen years old and after only two weeks of daily sexually abusive encounters with Defendant. Defendant used his private jet to transport the minor Plaintiff to Manhattan, where he provided her with spending money and accommodations with him at his mansion. From the time that Plaintiff was 15 years old, Defendant abused her to serve his every sexual whim, obtaining and purchasing passports and whatever was needed for her to travel with him and/or for him. Defendant transported Plaintiff in his private jet to locations that included Palm Beach, New York City, Santa Fe, Los Angeles, San Francisco, St. Louis, and numerous other domestic destinations, as well as international**  destinations, including Europe, the Caribbean, and Africa. He provided accommodations with him in order to have her available to him at all times wherever he went, including while transporting the minor Plaintiff on his private jet. Each time they would travel to one of these destinations, the same pattern of sexual abuse would occur, often with a vast array of aspiring models, actresses, celebrities, and/or other females, including minors, from all over the world. Upon information and belief, Defendant transported minor girls from Turkey, the Czech Republic, Asia, and numerous other countries, many of whom spoke no English. To Plaintiff's knowledge, the only females specifically excluded from Defendant's sexual escapades were African-Americans.
+
+21. In addition to being continually exploited to satisfy Defendant's every sexual whim, Plaintiff was also required to be sexually exploited by Defendant's adult male peers, including royalty, politicians, academicians, businessmen, and/or other professional and personal acquaintances. Whenever Defendant transported Plaintiff with him in destination, Defendant would pay Plaintiff a flat rate per day while mentioned associates would sexually exploit and abuse minor Plaintiff. his private jet to any he and/or his above-
+
+22. Most of these acts of abuse occurred during a time when Defendant knew that Plaintiff was approximately 15, 16, and 17 years old, and, after years of daily sexual exploitation, continued into her adulthood. Despite Defendant's stating shortly before Plaintiff's sixteenth birthday that he soon would have to trade her in because she was getting too old, Defendant continued to sexually exploit Plaintiff until she fed at age 19. Defendant's predilection for young girls was well known to those who regularly procured them for him and to his circle of friends. On one of Defendant's birthdays, a friend of Defendant sent him three 12-year-old girls from France who spoke no English for Defendant to sexually exploit and abuse. After doing so, they were sent back to France the next day.
+
+23. Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by 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 and Ms. Maxwell acknowledged and celebrated Plaintiff's I6th birthday. Defendant's preference for underage girls was well-known to those who regularly procured them for him.
+
+24. As previously stated in paragraph 14, Defendant displayed nude photographs of underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of Defendant's homes, including a photograph of herself naked at Defendant's home in Palm Beach. When she asked Defendant about it, he stated dismissively that he had naked photographs of her in all of his homes.
+
+25. Upon information and belief, some of the photographs in Defendant's possession 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 may have taken lewd photographs of Plaintiff, Jane Doe No. 102, 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. In addition, while Plaintiff was a minor teenager and upon Ms. Maxwell's insistence after Ms. Maxwell rejected as inappropriate photographs that Plaintiff presented of herself fully clothed, Ms. Maxwell photographed Plaintiff naked in different sexually explicit positions. Ms. Maxwell then presented these nude photographs of Plaintiff to Defendant as a birthday present for Defendant from Ms. Maxwell.
+
+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 Sheriff's Office 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.
+
+26. It is virtually impossible to calculate the exact number of times that Defendant sexually exploited and abused Plaintiff. From the age of IS, Plaintiff was sexually exploited and abused by Defendant on a daily basis and, most often, multiple times each day. While some of the precise dates these acts occurred are unknown to Plaintiff, these dates are known to Defendant, as he is reported to have kept a written log of each instance in which he engaged in these lewd acts with then minor Plaintiff and others. Upon information and belief, these logs are also in the custody of law enforcement.
+
+27. In or around September 2002, Defendant purchased a commercial round-trip airline ticket, and provided a passport, U.S. currency, and accommodations for Plaintiff to fly to Thailand. While thousands of miles away from Defendant on this extended trip alone for the first time in more than four years, Plaintiff met, fell in love, and married a young man. She escaped from Defendant's abuse with the help and insistence of her new husband and, instead of returning to Defendant, boarded a plane to Australia with one suitcase.
+
+28. Since November 2002, Plaintiff has lived a modest life in Australia, while maintaining lines of communication with her family and without contact with Defendant or any of the people in his entourage. However, suddenly, in 2008, Plaintiff received numerous phone calls from one of Defendant's agents. During these phone calls to Plaintiff, he repeatedly asked whether she knew anything about the civil cases against Defendant, whether she knew any of the females who were proceeding with the civil suits, whether she was planning on filing suit, whether she was communicating and/or cooperating with anyone against Defendant, and whether she would return to the United States to testify. Terrified by Defendant's demonstrated ability to track her down on her changed cell phone number halfway across the world, Plaintiff attempted to reassure Defendant's agent that she would remain quiet. During the course of one of these phone calls from Defendant's agents, Defendant himself spoke on the phone, continued to question her intentions, and, upon being reassured by Plaintiff, thanked her for not getting involved.
+
+29. Around January 2009, Plaintiff received a letter from the United States Attorney's Office for the Southern District of Florida, informing her of her potential civil claims against Defendant under 18 U.S.C. § 2255. Plaintiff contacted undersigned counsel within days and diligently and repeatedly pursued a good faith viable settlement of her claims against Defendant. Unable to reach a settlement, this lawsuit followed.
+
+30. As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 102, 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, separation from her family, and other damages associated with Defendant's controlling and manipulating her on a daily basis Sr years into a perverse and unhealthy way of life.
+
+31. Defendant, Jeffrey Epstein, committed the above-referenced acts upon 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. § 2421, § 2422(a), § 2422(b), § 2423(a), § 2423(b), § 2423(e), § 2251, § 2252, § 2252A(a)(1), and § 2252A(gX1).
+
+32. 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. 102. 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 Enzaze in Prostitution or Sexual Activity pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 2422(13))
+
+33. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, reallcges, and incorporates by reference the allegations contained in paragraphs I through 32 above.
+
+34. Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign commerce to knowingly persuade, induce, entice, or coerce Jane Doe No. 102, 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).
+
+35. Plaintiff, Jane Doe No. 102, 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, separation from her family, 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. 102, 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 Transportation of Minor with Intent to Engage in Criminal Sexual Activity pursuant to 18 1:.S.C.\$ 2255 in Violation of 18 U.S.C. & 2423(a)1
+
+37. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above.
+
+38. Defendant, Jeffrey Epstein, knowingly transported then minor Plaintiff, Jane Doe No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, in violation 18 U.S.C. § 2423(a). As previously stated in paragraphs 20, 21, and 27, Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across international borders numerous times from the time that Plaintiff was merely 15 years old through adulthood with the primary intent of sexually exploiting her.
+
+39. Plaintiff, Jane Doe No. 102, 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.
+
+40. 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, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life for a minor. 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. 102, 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 Travel with Intent to Eneaee in Illicit Sexual Conduct pursuant to 18 U.S.C. 8 2255 in Violation of 18 U.S.C. 6 2423(b11
+
+41. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above.
+
+42. Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate and/or foreign commerce with the intent to engage 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).
+
+43. Plaintiff, Jane Doe No. 102, 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 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, separation from her family, 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. 102, 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 Coercion and Enticement to Emu in Prostitution or Sexual Activity pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 2422(a)1
+
+45. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs I through 32 above.
+
+46. Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, and/or coerced Jane Doe No. 102 to travel in interstate and/or foreign commerce 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(a).
+
+47. Plaintiff, Jane Doe No. 102, 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. 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, separation from her family, 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. 102, 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 "Transportation with Intent to Enzaze in Criminal Sexual Activity pursuant to 18 U.S.C. Ft 2255 in Violation of 18 U.S.C. 24211
+
+49. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above.
+
+50. Defendant, Jeffrey Epstein, knowingly transported, or attempted to transport, Plaintiff, Jane Doe No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff engage in prostitution and/or in any sexual activity for which any person can be charged with a criminal offense, in violation of 18 U.S.C. § 2421. As previously stated in paragraphs 20, 21, and 27, Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across international borders numerous times from the time that Plaintiff was merely 15 years old through adulthood with the primary intent of sexually exploiting her.
+
+51. Plaintiff, Jane Doe No. 102, 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.
+
+52. 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, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life for a minor. 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. 102, 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 Sexual Exploitation of Children pursuant to 18 U.S.C. ti 2255 in Violation of 18 U.S.C. \$ 22511
+
+53. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, rcalleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above.
+
+54. Defendant. Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the then minor Plaintiff 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, 24, and 25, Defendant kept and 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. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of Defendant's homes, including a photograph of herself naked at Defendant's home in Palm
+
+Beach. 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. 102, 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 Sheriff's Office 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.
+
+55. Plaintiff, Jane Doe No. 102, 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.
+
+56. 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, separation from her family, 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. 102, 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 Transport of Visual Depiction of Minor Enenine in Sexually Explicit Conduct pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 2252(a)f1D
+
+57. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above.
+
+58. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via computer and/or facsimile in or affecting interstate and/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(O1). As previously stated in paragraphs 14, 24, and 25, 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. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of Defendant's homes, including a photograph of herself naked as a minor at Defendant's home in Palm Beach. As previously stated in paragraph 24, Defendant told Plaintiff that he had photographs of her naked in all of his homes. 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. 102, 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 Sheriff's Office 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.
+
+59. As previously stated in paragraph 23, any assertions by Defendant that he was unawarc 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.
+
+60. Plaintiff, Jane Doe No. 102, 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.
+
+61. 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, separation from her family, 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. 102, 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 EIGHT (Cause of Action for Transport of Child Pornoeraphv pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. 4 2252A(a)(1)1
+
+62. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above.
+
+63. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via computer and/or facsimile in or affecting interstate and/or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1).
+
+64. Plaintiff, Jane Doe No. 102, 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.
+
+65. 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, separation from her family, 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. 102, 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 NINE (Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. 2255 in Violation of 18 U.S.C. 4 2252A(2)1
+
+66. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above and Counts One through Eight above.
+
+67. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, as defined in 18 U.S.C. § 2252A(gX2), in violation of 18 U.S.C. § 2252A(gX1). As more fully set forth 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(AXaX1)), and Chapter 117 (transportation for illegal sexual activity in violation of 18 U.S.C. §§ 2421, 2422, and 2423). As more fully set forth above in paragraphs 9 through 32, Defendant's actions involved countless victims and countless separate incidents of sexual abuse, which he committed against minors, including Plaintiff, in concert with at least three other persons.
+
+68. Plaintiff, Jane Doe No. 102, 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.
+
+69. 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, separation from her family, 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. 102, 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
+
+Cu-x ! Pirs44—s-lre.•6. \_12 E Robert C. JosefsWerg, Bar No. 0408563 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) riosefsberiapodhurst.com
+
+kezelltilpodhurst.corn
+
+Attorneys for Plaintiff
+
+### DEMAND FOR JURY TRIAL
+
+Plaintiff demands to have her case tried before a jury.
+
+8660 • frit-kk-Zr
+
+Robert C. Josetnerg, 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
+
+kezellApodhurst.com
+
+Attorneys for Plaintiff
+
+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. 102
+
+(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.  
+Podhurst Orseck, P.A.  
+25 W. Flagler St., Suite 800  
+Miami FL 33130  
+**09-cv-80656-Ruskamp**
+
+(d) Check County Where Action Arose:  MIAMI-DADE  MONROE  BROWARD  PALM BEACH  ST. LUCIE  INDIAN  SCROVE  LA MAMCHOBE  
+**Virginia**
+
+**DEFENDANTS**
+
+Jeffrey Epstein
+
+County of Residence of First Listed Defendant West Palm Beach  
+(IN U.S. PLAINTIFF CASES ONLY)
+
+NOTE: IN LAND CONDEMNATION CASES USE THE LOCATION OF THE DEFENDANT INTAKE  
+**SEE 60 by LOCATION OF THE DEFENDANT**
+
+Attorneys (If Known)
+
+Jack A. Goldberger, Esq., Atterbury, Goldberger, et al., 250 S. Australian Ave., #1400, West Palm Beach, FL 34130  
+**CLERK U.S. DIST. CT**  
+**SCROVE FL MAMCHOBE**  
+**HIGHLANDS**
+
+**II. BASIS OF JURISDICTION** (Place an "X" in One Box Only)
+
+ 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** (Place an "X" in One Box for Plaintiff and One Box for Defendant)
+
+(For Diversity Cases Only)
+
+|                                         | PTF                        | DEF                                   | PTF                                                           | DEF                        |                            |
+|-----------------------------------------|----------------------------|---------------------------------------|---------------------------------------------------------------|----------------------------|----------------------------|
+| Citizen of This State                   | <input type="checkbox"/> 1 | <input checked="" type="checkbox"/> 1 | Incorporated or Principal Place of Business In This State     | <input type="checkbox"/> 4 | <input type="checkbox"/> 4 |
+| Citizen of Another State                | <input type="checkbox"/> 2 | <input type="checkbox"/> 2            | Incorporated and Principal Place of Business In Another State | <input type="checkbox"/> 5 | <input type="checkbox"/> 5 |
+| Citizen or Subject of a Foreign Country | <input type="checkbox"/> 3 | <input type="checkbox"/> 3            | Foreign Nation                                                | <input type="checkbox"/> 6 | <input type="checkbox"/> 6 |
+
+**IV. NATURE OF SUIT** (Place an "X" in One Box Only)
+
+| CONTRACT                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | TORTS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | FORFEITURE/PENALTY                                                                                                                                                                                                                                                                                                                                                                                                                                                     | BANKRUPTCY                                                                                                                                                                                                                                                                                                                                                                                                     | OTHER STATUTES                                                                                                                                                                                                                                                                                                                                                                                          |                 |  |                                         |                                     |                                        |                                        |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |
+|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------|--|-----------------------------------------|-------------------------------------|----------------------------------------|----------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| <input type="checkbox"/> 110 Insurance<br><input type="checkbox"/> 120 Marine<br><input type="checkbox"/> 130 Act<br><input type="checkbox"/> 140 Negotiable Instrument<br><input type="checkbox"/> 150 Recovery of Overpayment & Enforcement of Judgment<br><input type="checkbox"/> 151 Medicare Act<br><input type="checkbox"/> 152 Recovery of Defaulted Student Loans (Excl. Veterans)<br><input type="checkbox"/> 153 Recovery of Overpayment of Veteran's Benefits<br><input type="checkbox"/> 160 Stockholders' Suits<br><input type="checkbox"/> 190 Other Contract<br><input type="checkbox"/> 195 Contract Product Liability<br><input type="checkbox"/> 196 Franchise | <b>PERSONAL INJURY</b><br><input type="checkbox"/> 310 Airplane<br><input type="checkbox"/> 315 Airplane Product Liability<br><input type="checkbox"/> 320 Assault, Libel & Slander<br><input type="checkbox"/> 330 Federal Employers' Liability<br><input type="checkbox"/> 340 Marine<br><input type="checkbox"/> 345 Marine Product Liability<br><input type="checkbox"/> 350 Motor Vehicle<br><input type="checkbox"/> 355 Motor Vehicle Product Liability<br><input checked="" type="checkbox"/> 360 Other Personal Injury | <b>PERSONAL INJURY</b><br><input type="checkbox"/> 362 Personal Injury - Med. Malpractice<br><input type="checkbox"/> 365 Personal Injury - Product Liability<br><input type="checkbox"/> 368 Asbestos Personal Injury Product Liability<br><input type="checkbox"/> 370 Other Fraud<br><input type="checkbox"/> 371 Truth in Lending<br><input type="checkbox"/> 380 Other Personal Property Damage<br><input type="checkbox"/> 385 Property Damage Product Liability | <input type="checkbox"/> 610 Agriculture<br><input type="checkbox"/> 620 Other Food & Drug<br><input type="checkbox"/> 625 Drug Related Seizure of Property 21 USC 881<br><input type="checkbox"/> 630 Liquor Laws<br><input type="checkbox"/> 640 R.R. & Truck<br><input type="checkbox"/> 650 Airline Regs.<br><input type="checkbox"/> 660 Occupational Safety/Health<br><input type="checkbox"/> 690 Other | <input type="checkbox"/> 422 Appeal 28 USC 158<br><input type="checkbox"/> 423 Withdrawal 28 USC 157<br><table border="1"> <tr> <th colspan="2">PROPERTY RIGHTS</th> </tr> <tr> <td><input type="checkbox"/> 820 Copyrights</td> <td><input type="checkbox"/> 830 Patent</td> </tr> <tr> <td><input type="checkbox"/> 840 Trademark</td> <td><input type="checkbox"/> 840 Trademark</td> </tr> </table> | PROPERTY RIGHTS |  | <input type="checkbox"/> 820 Copyrights | <input type="checkbox"/> 830 Patent | <input type="checkbox"/> 840 Trademark | <input type="checkbox"/> 840 Trademark | <input type="checkbox"/> 480 Consumer Credit<br><input type="checkbox"/> 490 Cable/Sat TV<br><input type="checkbox"/> 810 Selective Service<br><input type="checkbox"/> 850 Securities/Commodities/Exchange<br><input type="checkbox"/> 875 Customer Challenge 12 USC 3410<br><input type="checkbox"/> 890 Other Statutory Actions<br><input type="checkbox"/> 891 Agricultural Acts<br><input type="checkbox"/> 892 Economic Stabilization Act<br><input type="checkbox"/> 893 Environmental Matters<br><input type="checkbox"/> 894 Energy Allocation Act<br><input type="checkbox"/> 895 Freedom of Information Act<br><input type="checkbox"/> 900 Appeal of Fee Determination Under Equal Access to Justice<br><input type="checkbox"/> 950 Constitutionality of State Statutes |
+| PROPERTY RIGHTS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                                                                                                                                                                                                                                                                                                                                                                                                |                                                                                                                                                                                                                                                                                                                                                                                                         |                 |  |                                         |                                     |                                        |                                        |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |
+| <input type="checkbox"/> 820 Copyrights                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | <input type="checkbox"/> 830 Patent                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                                                                                                                                                                                                                                                                                                                                                                                                |                                                                                                                                                                                                                                                                                                                                                                                                         |                 |  |                                         |                                     |                                        |                                        |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |
+| <input type="checkbox"/> 840 Trademark                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | <input type="checkbox"/> 840 Trademark                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                                                                                                                                                                                                                                                                                                                                                                                                |                                                                                                                                                                                                                                                                                                                                                                                                         |                 |  |                                         |                                     |                                        |                                        |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |
+| REAL PROPERTY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | CIVIL RIGHTS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | PRISONER PETITIONS                                                                                                                                                                                                                                                                                                                                                                                                                                                     | LABOR                                                                                                                                                                                                                                                                                                                                                                                                          | SOCIAL SECURITY                                                                                                                                                                                                                                                                                                                                                                                         |                 |  |                                         |                                     |                                        |                                        |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |
+| <input type="checkbox"/> 210 Land Condemnation<br><input type="checkbox"/> 220 Foreclosure<br><input type="checkbox"/> 230 Rent Lease & Ejectment<br><input type="checkbox"/> 240 Torts to Land<br><input type="checkbox"/> 245 Tort Product Liability<br><input type="checkbox"/> 290 All Other Real Property                                                                                                                                                                                                                                                                                                                                                                    | <input type="checkbox"/> 441 Voting<br><input type="checkbox"/> 442 Employment<br><input type="checkbox"/> 443 Housing/Accommodations<br><input type="checkbox"/> 444 Welfare<br><input type="checkbox"/> 445 Amer. w/Disabilities - Employment<br><input type="checkbox"/> 446 Amer. w/Disabilities - Other<br><input type="checkbox"/> 440 Other Civil Rights                                                                                                                                                                 | <input type="checkbox"/> 510 Motions to Vacate Sentence<br><b>Habeas Corpus:</b><br><input type="checkbox"/> 530 General<br><input type="checkbox"/> 535 Death Penalty<br><input type="checkbox"/> 540 Mandamus & Other<br><input type="checkbox"/> 550 Civil Rights<br><input type="checkbox"/> 555 Prison Condition                                                                                                                                                  | <input type="checkbox"/> 710 Fair Labor Standards Act<br><input type="checkbox"/> 720 Labor/Mgmt. Relations<br><input type="checkbox"/> 730 Labor/Mgmt. Reporting & Disclosure Act<br><input type="checkbox"/> 740 Railway Labor Act<br><input type="checkbox"/> 790 Other Labor Litigation<br><input type="checkbox"/> 791 Empl. Ret. Inc. Security Act                                                       | <input type="checkbox"/> 861 HIA (1395ff)<br><input type="checkbox"/> 862 Black Lung (923)<br><input type="checkbox"/> 863 DIWC/DIWW (405(g))<br><input type="checkbox"/> 864 SSID Title XVI<br><input type="checkbox"/> 865 RSI (405(g))<br><input type="checkbox"/> 870 Taxes (U.S. Plaintiff or Defendant)<br><input type="checkbox"/> 871 IRS—Third Party 26 USC 7609                               |                 |  |                                         |                                     |                                        |                                        |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |
+
+**V. ORIGIN** (Place an "X" in One Box Only)  
+ 1 Original Proceeding  2 Removed from State Court  3 Re-filed-(see VI below)  4 Reinstated or Reopened  5 Transferred from another district (specify)  6 Multidistrict Litigation  7 Appeal to District Judge from Magistrate Judgment
+
+**VI. RELATED/RE-FILED CASE(S).**
+
+(See instructions second page): JUDGE Kenneth A. Marra DOCKET NUMBER See Attached
+
+**VII. CAUSE OF ACTION** Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity):  
+ 18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b), 2423(b), 2423(e), 2251, 2252, 2252A(a)(1), 2252A(g)(1))  
+ LENGTH OF TRIAL via 4 days estimated (for both sides to try entire case)
+
+**VIII. REQUESTED IN COMPLAINT:**  CHECK IF THIS IS A CLASS ACTION UNDER F.R.C.P. 23 **DEMAND \$** CHECK YES only if demanded in complaint: **JURY DEMAND:**  Yes  No
+
+ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE SIGNATURE OF ATTORNEY OF RECORD DATE **5/1/09**  
+**FOR OFFICE USE ONLY**  
+ AMOUNT **A350.00** RECEIPT # **9100030**  
+**05/01/09**
+
+# UNITED STATES DISTRICT COURT SOUTIIERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION
+
+# ATTACHMENT TO CIVIL COVER SHEET
+
+FOR: Jane Doe 10tv. Jeffrey Epstein
+
+VI: RELATED/RE-FIELD CASE(S):
+
+08-80069
+
+08-80119
+
+08-80232
+
+08-80380
+
+08-80381
+
+08-08804
+
+08-80811
+
+08-80893
+
+08-80993
+
+08-80994
+
+08-80469
+
+09-80591

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+        "title": "COUNT ONE \n(Cause of Action for Coercion and Enticement of Minor to Enzaze in Prostitution or \nSexual Activity pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 2422(13))",
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+        "heading_level": null,
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+        "title": "COUNT THREE",
+        "heading_level": null,
+        "page_id": 14,
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+      },
+      {
+        "title": "(Cause of Action for Travel with Intent to Eneaee in Illicit Sexual Conduct pursuant to 18 \nU.S.C. 8 2255 in Violation of 18 U.S.C. 6 2423(b11",
+        "heading_level": null,
+        "page_id": 14,
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+          [
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+        "title": "COUNT FIVE \n(Cause of Action for \"Transportation with Intent to Enzaze in Criminal Sexual Activity \npursuant to 18 U.S.C. Ft 2255 in Violation of 18 U.S.C. 24211",
+        "heading_level": null,
+        "page_id": 16,
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+      {
+        "title": "COUNT SIX \n(Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. ti 2255 in \nViolation of 18 U.S.C. $ 22511",
+        "heading_level": null,
+        "page_id": 17,
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+            469.7005615234375
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+      {
+        "title": "COUNT SEVEN",
+        "heading_level": null,
+        "page_id": 19,
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+            309.1040344238281
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+            309.1040344238281
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+      {
+        "title": "(Cause of Action for Transport of Visual Depiction of Minor Enenine in Sexually Explicit \nConduct pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 2252(a)f1D",
+        "heading_level": null,
+        "page_id": 19,
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+      {
+        "title": "COUNT EIGHT \n(Cause of Action for Transport of Child Pornoeraphv pursuant to 18 U.S.C. & 2255 in \nViolation of 18 U.S.C. 4 2252A(a)(1)1",
+        "heading_level": null,
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+      {
+        "title": "COUNT NINE \n(Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. \n2255 in Violation of 18 U.S.C. 4 2252A(2)1",
+        "heading_level": null,
+        "page_id": 22,
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+            389.4735412597656
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+            389.4735412597656
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+      {
+        "title": "DEMAND FOR JURY TRIAL",
+        "heading_level": null,
+        "page_id": 24,
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+        "heading_level": null,
+        "page_id": 25,
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+            43.74
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marker2/court-doe-102-v-epstein/EFTA02738761/EFTA02738761.md

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+## UNITED STATES DISTRICTCOURT
+
+Southern District of Florida
+
+Case Number:
+
+JANE DOE 102
+
+v.
+
+JEFFREY EPSTEIN
+
+Plaintiff
+
+Defendant
+
+09-80656
+
+CIV-RYSKAMP
+
+## SUMMONS IN A CIVIL CASE
+
+MAGISTRATE JUDGE VITUNAC
+
+TO:0:ameandatmgmopkrmunu
+
+Jeffrey Epstein
+
+Palm Beach County Stockade
+
+West Palm Beach, FL
+
+and/or by serving his counsel:
+
+Jack A. Goldberger, Esq., 250 S. Australian 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. Josefsberg, Esq./Katherine W. E2e11, Esq.
+
+Podhurst Orseck, P.A.
+
+25 W. Flagler St., Suite 800
+
+Miami, FL 33130
+
+20
+
+an answer to the complaint which is herewith screed 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
+
+CLERK OF COURT DATE
+
+MAY 1 2009
+
+PbAktubvi (BY) DEPUTY CLERK

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marker2/court-doe-102-v-epstein/EFTA02738762/EFTA02738762.md

@@ -0,0 +1,132 @@
+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 09-80656-CIV-Ryskamp
+
+JANE DOE No. 102,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant,
+
+# RESPONSE IN OPPOSITION TO MOTION TO PROCEED ANONYMOUSLY
+
+### AND
+
+#### EPSTEIN'S MOTION TO COMPEL AND/OR IDENTIFY JANE DOE #102 IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE #102 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 #102'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 #102 ("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 May 1, 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 Transportation With Intent to Engage in Illicit Sexual Conduct Pursuant to Pursuant to 18 U.S.C. H2255 and 2423(a); Count III — Cause of Action for Travel with Intent to Engage In Illicit Sexual Conduct Pursuant to 18 U.S.C. §§2255 and 2423(b); Count IV — Coercion and Enticement of a Minor to Engage in Prostitution or Sexual Activity Pursuant to 18 U.S.C. §§2255 and 2422(a); Count V — Cause of Action for Transportation with Intent to Engage in Criminal Sexual Activity Pursuant to 18 U.S.C. H2255 and 2421; Count VI — Cause of Action for Sexual Exploitation of Children Pursuant to 18 U.S.C. H2255 and 2255; Count VII — Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit Conduct Pursuant to 18 U.S.C. §§2255 and 2252(a)(1)): Count VIII — Cause of Action for Transport of Child Pornography Pursuant to 18 U.S.C. §§2255 and 2252A(a)(1));
+
+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, separation from her family . . . , 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 ¶¶36, 40, 44, 48, 52, 56, 61, 65, and 69, 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 Plaintiffs 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 Plaintiffs 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 plaintiff's 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 v. M, 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 by failing to identify Jane Doe in various third-party subpoenas to her medical providers and other third parties, Epstein will be prevented from defending this case.
+
+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 Plaintiff's 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, separation from her family . , 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 Plaintiff's 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 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, separation from her family . . . , 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.
+
+> ROBE D. CRITTON, 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 \_EL 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/court-doe-102-v-epstein/EFTA02738774/EFTA02738774.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 09-80656-RYSKAMPNITUNAC
+
+JANE DOE No. 102,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant,
+
+## NOTICE OF APPEARANCE
+
+The undersigned attorneys hereby file behalf of the Defendant, JEFFREY EPSTEIN, in <sup>t</sup> <sup>n</sup>pearance as counsel on styled matter.
+
+> By: RO: ITTON, JR., ESQ. Florida ar No. 224162 rcrit bcIclaw. •m MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpikeebciclaw.com
+
+## Certificate of Service
+
+<sup>I</sup>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 recor <sup>4</sup> <sup>4</sup> identified on the following Service List in the manner specified by CM/ECF on this ay of May, <sup>2009</sup>
+
+Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. <sup>25</sup>West Flagler Street, Suite 800 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400
+
+Doe 102 v. Epstein Page 2
+
+Miami, FL 33130 305 358-2800 Fax: 305 358-2382 riosefsbera@podhurst.com kezellapodhurst.com Counsel for Plaintiff
+
+West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jacieseabellsouth.net Counsel for f efendant Jeffrey Epstein
+
+Respectfu ed,
+
+By: ROB ON, JR., ESQ. Florida Bar No. 24162 rcritabcIclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 moikeabc1claw.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/court-doe-102-v-epstein/EFTA02738776/EFTA02738776.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 09-80656-CIV-RYSKAMPNITUNAC
+
+JANE DOE NO. 102,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+## ORDER OF TRANSFER
+
+THIS CAUSE comes before the Court sua sponse. The above-styled case is related to multiple actions pending before the Honorable Kenneth A. Marra that have been filed against Defendant Jeffrey Epstein. Pursuant to Local Rule 3.9, it is hereby
+
+ORDERED AND ADJUDGED that the above numbered case is hereby
+
+TRANSFERRED to the Honorable Kenneth A. Marra.
+
+DONE AND ORDERED in May, 2009. at West Palm Beach, Florida, this /a day of
+
+> NNETH L. RYS UNITED STATES DISTRICT JUDGE
+
+After reviewing the Court file in the above numbered Cause, the undersigned hereby accepts the transfer of said case. Therefore, it is
+
+ORDERED AND ADJUDGED that all pleadings hereinafter filed shall bear the following case number, 09-80656-CIV-MARRA, thereby indicating the Judge to whom all pleadings should be routed or otherwise brought for attention.
+
+THE FOREGOING transfer is herewith accepted this 13 day of May, 2009.
+
+KENNETH A. MARRA UNITED STATES DISTRICT JUDGE

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marker2/court-doe-102-v-epstein/EFTA02738778/EFTA02738778.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 3,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80119-MARRA
+
+CASE NO.: 08-CV-80232-MARRA
+
+/
+
+JANE DOE NO. 4,
+
+Plaintiff,
+
+vs. JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+CASE NO.: 08-CV-80380-MARRA
+
+CASE NO.: 08-CV-80381-MARRA/
+
+Defendant.
+
+JANE DOE NO. 6,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-80994-CIV-MARRA/M.
+
+JANE DOE NO. 7, CASE NO.: 08-80993-CIV-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+C.M.A., CASE NO.: 08-8081 I -CIV-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08- 80893-CIV-MARRA/
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+DOE II, CASE NO.: 09- 80469-CIV-MARRA/=I.
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+JANE DOE NO. 101, CASE NO.: 09- 80591-CTV-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 102 CASE NO.: 09- 80656-CIV-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## 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</sup> 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/court-doe-102-v-epstein/EFTA02738783/EFTA02738783.md

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+**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 Motion To Stay And Or Continue Action For Time Certain Based On  
+Parallel Civil And Criminal Proceedings 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 a time 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 a motion 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 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 a stay of this civil action until the criminal matter in the 15<sup>th</sup> 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</sup>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 USA() 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</sup>WL 3392207 (S.D. Fla. 2006), citing United States v. Lot 5, Fox Grove, <sup>23</sup>F.3d 359 (11th Cir. 1994). In Ventura, <sup>a</sup>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 1.122 Securities and Exchange Commission, <sup>755</sup>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 56 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), citin 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
+
+Page 8
+
+Clause of the Fourteenth Amendment - "tilt 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 als2 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.Q. 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. Apfelbaum, 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 24th day of March , 2009
+
+Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff C.M.A. reelrhw@botmail.com
+
+Jack Scarola, Esq. Jack P.M, 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(asearcvlaw.com jtahQsearcvlaw.com Co-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 iauescabellsouth.net Counsel for Defendant Jeffrey Epstein
+
+Bruce Reinhart, Esq. Bruce E. Reinhart, P.A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 ecf Couns• fo 'efendant
+
+Hee'
+
+Florida = ar No. 224 rcrit@bc1claw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mnike(4bc1claw.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)
+
+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.
+
+![]()![]()EXHIBIT "A"
+
+Leffrey 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.
+
+EXHIBIT
+
+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</sup> day of February, 2009.
+
+![](_page_18_Picture_18.jpeg)
+
+![]()
+
+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CV-80811-MARRA/
+
+C.M. A.,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN and
+
+Defendants,
+
+### DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION
+
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, hereby responds to Plaintiffs 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
+
+> tic / EXHIBIT e-Si 4k
+
+r ,-..\s' (h a, pn(
+
+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
+
+isx searcvlaw.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
+
+West Palm Beach, FL 33401
+
+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
+
+mpike(d).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/court-doe-102-v-epstein/EFTA02738807/EFTA02738807.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 3,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 4,
+
+Plaintiff,
+
+vs. JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+CASE NO.: 08-CV-80119-MARRAi
+
+CASE NO.: 013-CV-80232-MARRA
+
+CASE NO.: 08-CV-80380-MARRA
+
+CASE NO.: 08-CV-80381-MARRA/
+
+Defendant.
+
+JANE DOE NO. 6,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 7,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-80994-CIV-MARRA
+
+CASE NO.: 08-80993-CIV-MARRA
+
+C.M.A., CASE NO.: 08-8081 I-CIV-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08- 80893-CIV-MARRA/
+
+Plaintiff,
+
+VS.
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+DOE II, CASE NO.: 09- 80469-CIV-MARRA/
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+JANE DOE NO. 101, CASE NO.: 09- 80591-CTV-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 102 CASE NO.: 09- 80656-CIV-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## 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 14th 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/court-doe-102-v-epstein/EFTA02738811/EFTA02738811.md

@@ -0,0 +1,199 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 3
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 4
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-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
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 7
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+C.M.A.
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80994-MARRA
+
+CASE NO.: 08-CV-80993-MARRA/
+
+CASE NO.: 08-CV-80811-MARRA/
+
+CASE NO.: 08-CV-80893-IVIARRA
+
+DOE II
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 101
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 102
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+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 El 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

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marker2/court-doe-102-v-epstein/EFTA02738817/EFTA02738817.md

@@ -0,0 +1,329 @@
+Case 9:08-cv-80804-KAM
+
+DEPARTMENT OF JUSTICE DEPARTMENT OF JUSTICE Page 3 of 8
+
+**PROPERTY RECEIPT**
+
+DETECTIVE BUREAU
+
+| PROPERTY NUMBER<br><b>05-368</b>                                                                                                                                                                               |          | DATE/TIME RECOVERED<br><b>10-20-2005</b>                                                                                                     |                                                                                                                                                          | PROPERTY NUMBER (Leave Blank)<br><b>05-1024</b> |              |  |
+|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------|----------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------|--------------|--|
+| ADDRESS WHERE PROPERTY IMPOUNDED<br><b>258 FL-Bullo</b>                                                                                                                                                        |          |                                                                                                                                              |                                                                                                                                                          |                                                 |              |  |
+| DISCOVERED BY / D.O.B.                                                                                                                                                                                         | ADDRESS  | Street                                                                                                                                       | City                                                                                                                                                     | Zip                                             | PHONE NUMBER |  |
+| OWNER / VICTIM'S NAME / D.O.B.                                                                                                                                                                                 | ADDRESS  | Street                                                                                                                                       | City                                                                                                                                                     | Zip                                             | PHONE NUMBER |  |
+| SUSPECT'S NAME / D.O.B.<br><b>Eostein Seff</b>                                                                                                                                                                 | ADDRESS  | Street                                                                                                                                       | City                                                                                                                                                     | Zip                                             | PHONE NUMBER |  |
+| ADDT IN SUSPECT / D.O.B.                                                                                                                                                                                       | ADDRESS  | Street                                                                                                                                       | City                                                                                                                                                     | Zip                                             | PHONE NUMBER |  |
+| SPECIAL INSTRUCTIONS                                                                                                                                                                                           |          |                                                                                                                                              | FOUND PROPERTY <input type="checkbox"/> CLAIM <input checked="" type="checkbox"/><br>DO DAYS <input type="checkbox"/> NOT CLAIM <input type="checkbox"/> |                                                 |              |  |
+| ITEM #                                                                                                                                                                                                         | QUANTITY | VALUE                                                                                                                                        | DESCRIPTION                                                                                                                                              |                                                 |              |  |
+| 1                                                                                                                                                                                                              | 1        |                                                                                                                                              | Phone message book (kitchen)                                                                                                                             |                                                 |              |  |
+| 2                                                                                                                                                                                                              | 2        |                                                                                                                                              | Phone message book (office off kitchen)                                                                                                                  |                                                 |              |  |
+| 3                                                                                                                                                                                                              | 3        |                                                                                                                                              | File folder (messages) w/ 2 mire files (Pure Paper)                                                                                                      |                                                 |              |  |
+| 4                                                                                                                                                                                                              | 1        |                                                                                                                                              | Shreddered paper marked message                                                                                                                          |                                                 |              |  |
+| 5                                                                                                                                                                                                              | 1        |                                                                                                                                              | orange kit folder marked message                                                                                                                         |                                                 |              |  |
+| 6                                                                                                                                                                                                              |          |                                                                                                                                              | x times 2-5 from office off kitchen                                                                                                                      |                                                 |              |  |
+| 7                                                                                                                                                                                                              |          |                                                                                                                                              | Black message table off from c/os office                                                                                                                 |                                                 |              |  |
+| 8                                                                                                                                                                                                              | 1        |                                                                                                                                              | Brown message table folder                                                                                                                               |                                                 |              |  |
+| 9                                                                                                                                                                                                              | 99       |                                                                                                                                              | Black framed photo of nude girl                                                                                                                          |                                                 |              |  |
+| 10                                                                                                                                                                                                             |          |                                                                                                                                              | Pictures in frame from above                                                                                                                             |                                                 |              |  |
+| 11                                                                                                                                                                                                             |          |                                                                                                                                              | 7 from yellow/blue room off kitchen off for x                                                                                                            |                                                 |              |  |
+| 12                                                                                                                                                                                                             | 8        |                                                                                                                                              | Photos from office off Part area                                                                                                                         |                                                 |              |  |
+| 13                                                                                                                                                                                                             | 2        |                                                                                                                                              | Photos from take/up and left to Heading Room off kitchen                                                                                                 |                                                 |              |  |
+| 14                                                                                                                                                                                                             | 2        |                                                                                                                                              | Photos in table on right to Part area                                                                                                                    |                                                 |              |  |
+| TOTAL PACKAGE WEIGHT                                                                                                                                                                                           |          |                                                                                                                                              |                                                                                                                                                          |                                                 |              |  |
+| I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt.                                                                                |          | I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer. |                                                                                                                                                          |                                                 |              |  |
+| SIGNATURE                                                                                                                                                                                                      | DATE     | SIGNATURE                                                                                                                                    | ID#                                                                                                                                                      | UNIT                                            |              |  |
+| RECEIVED BY                                                                                                                                                                                                    |          | REASON                                                                                                                                       | DATE/TIME RECEIVED                                                                                                                                       |                                                 |              |  |
+| I, Joseph Becaray, the officer by whom this warrant was executed, do swear that the above inventory contains a true and detailed account of all the property taken by me, under the authority of this warrant. |          |                                                                                                                                              |                                                                                                                                                          |                                                 |              |  |
+| Sworn to and subscribed before me this 21 day of October 2005.                                                                                                                                                 |          |                                                                                                                                              |                                                                                                                                                          |                                                 |              |  |
+
+**EXHIBIT**  
+*"A"*
+
+Case 9:08-cv-80804-KAM
+
+Document 12-2 Entered on FLSD Docket 08/21/2008 Page 4 of 8
+
+**PLAN BEACH POLICE DEPARTMENT**
+
+**PROPERTY RECEIPT  
+SEARCH WARRANT RETURN**
+
+**DETECTIVE BUREAU**
+
+Per Po Form #22
+
+| <input type="checkbox"/> PROPERTY            | <input type="checkbox"/> FOUND            | <input type="checkbox"/> DECEASED (Prebeloded) | <input type="checkbox"/> PERSONAL         | <input type="checkbox"/> CONFISCATED | <input type="checkbox"/> DESTROY |
+|----------------------------------------------|-------------------------------------------|------------------------------------------------|-------------------------------------------|--------------------------------------|----------------------------------|
+| <input checked="" type="checkbox"/> EVIDENCE | <input checked="" type="checkbox"/> TRIAL | <input type="checkbox"/> LABORATORY            | <input type="checkbox"/> STOLEN/RECOVERED | <input type="checkbox"/> OTHER       |                                  |
+
+| INCIDENT/CITATION NUMBER<br><b>05-368</b> | DATE/TIME RECOVERED<br><b>10:20-05</b> | PROPERTY NUMBER (Leave Blank)<br><b>05-1024</b> | BIN NUMBER (Leave Blank)<br><b>06b</b> |
+|-------------------------------------------|----------------------------------------|-------------------------------------------------|----------------------------------------|
+|-------------------------------------------|----------------------------------------|-------------------------------------------------|----------------------------------------|
+
+ADDRESS WHERE PROPERTY IMPOUNDED  
+**358 EL-Brillo**
+
+| DISCOVERED BY / D.O.B. | ADDRESS | Street | City | Zip | PHONE NUMBER |
+|------------------------|---------|--------|------|-----|--------------|
+|------------------------|---------|--------|------|-----|--------------|
+
+| OWNER / VICTIM'S NAME / D.O.B. | ADDRESS | Street | City | Zip | PHONE NUMBER |
+|--------------------------------|---------|--------|------|-----|--------------|
+|--------------------------------|---------|--------|------|-----|--------------|
+
+| SUSPECT'S NAME / D.O.B.<br><b>Fostin J.Ff</b> | ADDRESS | Street | City | Zip | PHONE NUMBER |
+|-----------------------------------------------|---------|--------|------|-----|--------------|
+|-----------------------------------------------|---------|--------|------|-----|--------------|
+
+| ADDITIONAL SUSPECT / D.O.B. | ADDRESS | Street | City | Zip | PHONE NUMBER |
+|-----------------------------|---------|--------|------|-----|--------------|
+|-----------------------------|---------|--------|------|-----|--------------|
+
+| SPECIAL INSTRUCTIONS | FOUND PROPERTY | CLAIM     |
+|----------------------|----------------|-----------|
+|                      | 60 DAYS        | NOT CLAIM |
+
+| ITEM#                | QUANTITY | VALUE                     | DESCRIPTION                                           |
+|----------------------|----------|---------------------------|-------------------------------------------------------|
+| 13                   | 2        | ✓                         | VHS trapes from (e data on feet By roof)              |
+| 14                   | 2        | *                         | CDS cacked High Birchdam ↑ Creditors page (3)         |
+| 15                   | 3        |                           | Photos framed from Cabarra                            |
+| 16                   | 1        | ✓                         | message book 1st floor S/W corner (top data)          |
+| 17                   | 1        | ✓                         | message book (from inside e)                          |
+| 18                   | 3        |                           | CDS from desk                                         |
+| 19                   | 1        | *                         | DV from desk (from * 1st floor 2)                     |
+| 20                   |          | unframed Photos from desk | from 1st floor S/W                                    |
+| 21                   | 2        |                           | framed Photos from desk                               |
+| 22                   | 2        | ✓                         | framed Photos from table in S/W corner (file cover)   |
+| 23                   | 3        |                           | Soap on Rope (NE Bedroom) (wh t copy)                 |
+| 24                   | 2        |                           | Tula Torpedo in Brown box                             |
+| 25                   | 2        |                           | Soap on Rope (middle Bedroom) (not framed)            |
+|                      | 1        |                           | large framed Picture (from foyet into Master Bedroom) |
+| TOTAL PACKAGE WEIGHT |          |                           | Bedroom                                               |
+
+I hereby acknowledge that the above let represents all property taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above let represents all property impounded by me in the official performance of my duty as a police officer.
+
+| SIGNATURE | DATE | SIGNATURE | ID# | UNIT |
+|-----------|------|-----------|-----|------|
+|           |      |           |     |      |
+
+| RECEIVED BY | REASON | DATE/TIME RECEIVED |
+|-------------|--------|--------------------|
+|             |        |                    |
+|             |        |                    |
+|             |        |                    |
+|             |        |                    |
+
+Case 9:08-cv-80804-KAM Document 12-2 Entered on FLSD Docket 08/24/2008 Page 5 of 8  
+**POLM BEACH POLICE DEPARTMENT**
+
+3 of 6
+
+**PROPERTY RECEIPT**  
+ SEARCH WARRANT RETURN
+
+DETECTIVE BUREAU
+
+| PRPD Form #32                                |                     | <input type="checkbox"/> PROPERTY         |                          | <input type="checkbox"/> FOUND      |  | <input type="checkbox"/> DECEASED (Probated) |  | <input type="checkbox"/> PERSONAL |  | <input type="checkbox"/> CONFISCATED |  | <input type="checkbox"/> DESTROY |  |
+|----------------------------------------------|---------------------|-------------------------------------------|--------------------------|-------------------------------------|--|----------------------------------------------|--|-----------------------------------|--|--------------------------------------|--|----------------------------------|--|
+| <input checked="" type="checkbox"/> EVIDENCE |                     | <input checked="" type="checkbox"/> TRIAL |                          | <input type="checkbox"/> LABORATORY |  | <input type="checkbox"/> STOLEN/RECOVERED    |  | <input type="checkbox"/> OTHER    |  | <input type="checkbox"/> OTHER       |  | <input type="checkbox"/> (ab)    |  |
+| INCIDENT/CITATION NUMBER                     | DATE/TIME RECOVERED | PROPERTY NUMBER (Leave Blank)             | BIN NUMBER (Leave Blank) |                                     |  |                                              |  |                                   |  |                                      |  |                                  |  |
+| 05-368                                       | 10-20-05            | 05-1024                                   |                          |                                     |  |                                              |  |                                   |  |                                      |  |                                  |  |
+
+ADDRESS WHERE PROPERTY IMPOUNDED  
+ 358 EL Brillo
+
+| DISCOVERED BY / D.O.B.           | ADDRESS        | Street | City | Zip | PHONE NUMBER |                          |
+|----------------------------------|----------------|--------|------|-----|--------------|--------------------------|
+| OWNER / VICTIM'S NAME / D.O.B.   | ADDRESS        | Street | City | Zip | PHONE NUMBER |                          |
+| SUSPECT'S NAME / D.O.B. Of 20-53 | ADDRESS        | Street | City | Zip | PHONE NUMBER |                          |
+| Eastern Joeff                    | 358 EL Brillo  |        |      |     |              |                          |
+| ADDITIONAL SUSPECT / D.O.B.      | ADDRESS        | Street | City | Zip | PHONE NUMBER |                          |
+|                                  |                |        |      |     |              |                          |
+| SPECIAL INSTRUCTIONS             | FOUND PROPERTY |        |      |     |              | CLAIM                    |
+| 80 DAYS                          |                |        |      |     | NOT CLAIM    | <input type="checkbox"/> |
+
+| ITEM #               | QUANTITY | VALUE | DESCRIPTION                                                                        |
+|----------------------|----------|-------|------------------------------------------------------------------------------------|
+| 23                   | 1        | NCV   | School TRANSCRIPT, ALEXANDER HALL, BIRSTER BROOM, DE SK                            |
+| 25                   | 1        | NCV   | BOTTLE OF JOY JALLY, MARTICE BROOM, CARDINELLA, MARTICE BROOM                      |
+| 129                  | 3        | NCV   | UNIDEOTAPES 1/2", SEXTIN CITY, EASTIN JANINE, LONG DE SPIANS FOUR, MASTER BATHROOM |
+| 130                  | 6        | NCV   | FRAMED PHOTO FROM NEWS BABIE SM - MARTICE BROOM                                    |
+| 331                  | 1        | NCV   | GREEN MASSACRE TABLE, DEN'S BATHROOM - MARTICE BROOM → DNA data 3 (copy)           |
+| 32                   | 1        | NCV   | THREFTY RENTAL AGREEMENT FROM CHEVROLET SUEMURBAN (COPIED)                         |
+| 33                   | 1        | NCV   | NOTE FROM JOHNANA FROM CHEVROLET SUEMURBAN                                         |
+| 34                   | 1        | CDS   | from office of P.K. Edward                                                         |
+| 35                   | 6        |       | ZIP CDS from Book case RETURN                                                      |
+| 36                   | 2        |       | 8 MM + deo toppes from Book case RETURN                                            |
+| 37                   | 4        |       | Compact Flash cards from Book case RETURN                                          |
+| 38                   | 1        |       | Flash card from Camera on book case → RETURN TO OURMAK                             |
+| 39                   | 3        |       | ZIP CDS from Book case RETURN                                                      |
+| 40                   | 36       |       | CDS from Book case (it was 35-40 from Buest house) RETURN                          |
+| TOTAL PACKAGE WEIGHT |          |       |                                                                                    |
+
+![]()Date 12-2-08 Entered on FLSD Docket 08/21/2008 Page 6 of 8
+
+**FLM BEACH POLICE DEPARTMENT**
+
+**PROPERTY RECEIPT**
+
+**DETECTIVE BUREAU**
+
+PRPD Form #55
+
+SEARCH WARRANTED RECEIVED
+
+| <input type="checkbox"/> PROPERTY                       |                                        | <input type="checkbox"/> FOUND                  | <input type="checkbox"/> DECEASED (Probated) | <input type="checkbox"/> PERSONAL         | <input type="checkbox"/> CONFISCATED | <input type="checkbox"/> DESTROY |
+|---------------------------------------------------------|----------------------------------------|-------------------------------------------------|----------------------------------------------|-------------------------------------------|--------------------------------------|----------------------------------|
+| <input checked="" type="checkbox"/> EVIDENCE            |                                        | <input checked="" type="checkbox"/> TRIAL       | <input type="checkbox"/> LABORATORY          | <input type="checkbox"/> STOLEN/RECOVERED | <input type="checkbox"/> OTHER       | <i>lab</i>                       |
+| INCIDENT/CITATION NUMBER<br><b>05-368</b>               | DATE/TIME RECOVERED<br><b>10-20-05</b> | PROPERTY NUMBER (Leave Blank)<br><b>05-1024</b> | BIN NUMBER (Leave Blank)                     |                                           |                                      |                                  |
+| ADDRESS WHERE PROPERTY IMPOUNDED<br><b>258 El Bullo</b> |                                        |                                                 |                                              |                                           |                                      |                                  |
+| DISCOVERED BY / D.O.B.                                  | ADDRESS                                | Street                                          | City                                         | Zip                                       | PHONE NUMBER                         |                                  |
+| OWNER'S NAME / D.O.B.                                   | ADDRESS                                | Street                                          | City                                         | Zip                                       | PHONE NUMBER                         |                                  |
+| SUSPECT'S NAME / D.O.B.<br><b>Eostein, Jeff</b>         | ADDRESS                                | Street                                          | City                                         | Zip                                       | PHONE NUMBER                         |                                  |
+| ADDRING SUSPECT / D.O.B.                                | ADDRESS                                | Street                                          | City                                         | Zip                                       | PHONE NUMBER                         |                                  |
+| SPECIAL INSTRUCTIONS                                    |                                        |                                                 |                                              |                                           | FOUND PROPERTY                       | CLAIM                            |
+|                                                         |                                        |                                                 |                                              |                                           | 60 DAYS                              | NOT CLAIM                        |
+
+| ITEM # | QUANTITY | VALUE | DESCRIPTION                                |
+|--------|----------|-------|--------------------------------------------|
+| 41     | 1        |       | Floppy disks from dock middle Shelf Return |
+| 42     | 1        |       | 2 in drive disk front bust room Return     |
+| 43     | 1        |       | Power Cord for CPU from bust room          |
+| 44     | 1        |       | CPU from bust Bedroom                      |
+| 45     | 10       |       | 8 mm video Tapes in bust Bedroom Return    |
+| 46     | 1        |       | Maxell CD-R in bust bedroom Return         |
+| 47     | BAIL     |       | Disks in clear Box Return                  |
+| 48     | 7        |       | ZIA DISKS from bust room Return            |
+| 49     | 1        |       | Items # 35-48 from bust bedroom Return     |
+| 50     | 1        |       | Missage book from bust house office Return |
+| 51     | 2        |       | nicsage book Return                        |
+| 52     | 6        |       | Compact flash cards from Return            |
+| 53     | 1        |       | CD's return #49-54 Return office Return    |
+
+**TOTAL PACKAGE WEIGHT**
+
+I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt.
+
+I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer.
+
+![]()Document 12-2 Entered on FLSD Docket 08/21/2008 Page 7 of 8  
+**PALM BEACH POLICE DEPARTMENT**  
+**PROPERTY RECEIPT**  
+**DETECTIVE BUREAU**
+
+POPD Form #52
+
+| <input type="checkbox"/> PROPERTY            | <input checked="" type="checkbox"/> FOUND | <input type="checkbox"/> DECEASED (Probable) | <input type="checkbox"/> PERSONAL         | <input type="checkbox"/> CONFISCATED | <input type="checkbox"/> DESTROY |
+|----------------------------------------------|-------------------------------------------|----------------------------------------------|-------------------------------------------|--------------------------------------|----------------------------------|
+| <input checked="" type="checkbox"/> EVIDENCE | <input checked="" type="checkbox"/> TRIAL | <input type="checkbox"/> LABORATORY          | <input type="checkbox"/> STOLEN/RECOVERED | <input type="checkbox"/> OTHER       | Cab                              |
+
+INCIDENT/CITATION NUMBER: **05-368** DATE/TIME RECOVERED: **10-20-05** PROPERTY NUMBER (Leave Blank): **05-1024** BIN NUMBER (Leave Blank):
+
+ADDRESS WHERE PROPERTY IMPOUNDED: **358 EL Brillo Palm Beach**
+
+DISCOVERED BY / D.O.B.: ADDRESS Street City Zip PHONE NUMBER
+
+OWNER'S NAME / D.O.B.: ADDRESS Street City Zip PHONE NUMBER
+
+SUSPECT'S NAME / D.O.B.: **Epstein Jeff 01-20-5** ADDRESS Street City Zip PHONE NUMBER
+
+ADDITIONAL SUSPECT / D.O.B.: ADDRESS Street City Zip PHONE NUMBER
+
+SPECIAL INSTRUCTIONS: FOUND PROPERTY (Leave Blank) CLAIM  90 DAYS NOT CLAIM 
+
+ITEM # QUANTITY VALUE DESCRIPTION
+
+| <b>54</b> | 1 | Power cord to CPU (#53)                         | Return |
+|-----------|---|-------------------------------------------------|--------|
+| <b>55</b> | 1 | CPU from office off Kitchen (Hall & Robinson)   | Return |
+| <b>56</b> | 1 | Power cord to item #55                          | Return |
+| <b>57</b> | 3 | CD's Arm #55-57 from Office off Kitchen Detroit | Return |
+| <b>58</b> | 1 | Peach mappage table upstages (Board & Board)    | Return |
+|           |   |                                                 | Return |
+|           |   |                                                 | Return |
+|           |   |                                                 | Return |
+|           |   |                                                 | Return |
+|           |   |                                                 | Return |
+|           |   |                                                 | Return |
+
+TOTAL PACKAGE WEIGHT
+
+I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt.
+
+I hereby acknowledge that the above list represents all property impounded from me in the official performance of my duty as a police officer.
+
+SIGNATURE
+
+DATE
+
+SIGNATURE
+
+ID#
+
+UNIT
+
+| RECEIVED BY | REASON | DATE/TIME RECEIVED |
+|-------------|--------|--------------------|
+|             |        |                    |
+|             |        |                    |
+|             |        |                    |
+|             |        |                    |
+|             |        |                    |
+|             |        |                    |
+|             |        |                    |
+
+Case 9:08-cv-80804-KAM Document 12-2 Entered on FLSD Docket 08/21/2008 Page 8 of 8
+
+**PALM BEACH POLICE DEPARTMENT**
+
+MAE 6 of 6
+
+**PROPERTY RECEIPT**
+
+*s/w Return*
+
+DETECTIVE BUREAU
+
+PRINT Form #82
+
+| <input type="checkbox"/> PROPERTY            | <input type="checkbox"/> FOUND             | <input type="checkbox"/> DECEASED (Probated)   | <input type="checkbox"/> PERSONAL         | <input type="checkbox"/> CONFISCATED | <input type="checkbox"/> DESTROY |
+|----------------------------------------------|--------------------------------------------|------------------------------------------------|-------------------------------------------|--------------------------------------|----------------------------------|
+| <input checked="" type="checkbox"/> EVIDENCE | <input checked="" type="checkbox"/> TRIAL  | <input type="checkbox"/> LABORATORY            | <input type="checkbox"/> STOLEN/RECOVERED | <input type="checkbox"/> OTHER       | <i>(ab)</i>                      |
+| INCIDENT/IDENTIFICATION NUMBER<br><i>05-</i> | DATE/TIME RECOVERED<br><i>10 2005 14/0</i> | PROPERTY NUMBER (Last Blank)<br><i>05-1024</i> | BIN NUMBER (Last Blank)                   |                                      |                                  |
+
+ADDRESS WHERE PROPERTY IMPOUNDED  
+*358 FL Bullo*
+
+| DISCOVERED BY / D.O.B.                      | ADDRESS                                                                                                           | Street | City | Zip | PHONE NUMBER |
+|---------------------------------------------|-------------------------------------------------------------------------------------------------------------------|--------|------|-----|--------------|
+| OWNER'S NAME / D.O.B.                       | ADDRESS                                                                                                           | Street | City | Zip | PHONE NUMBER |
+| SUSPECT'S NAME / D.O.B. / <i>RESTAURANT</i> | ADDRESS                                                                                                           | Street | City | Zip | PHONE NUMBER |
+| ADDITING SUSPECT / D.O.B.                   | ADDRESS                                                                                                           | Street | City | Zip | PHONE NUMBER |
+| SPECIAL INSTRUCTIONS                        | FOUND PROPERTY 80 DAYS <input type="checkbox"/> CLAIM <input type="checkbox"/> NOT CLAIM <input type="checkbox"/> |        |      |     |              |
+
+| ITEM # | QUANTITY | VALUE | DESCRIPTION                   |
+|--------|----------|-------|-------------------------------|
+| 9      | 1        | *     | GREEN DATO FLAVOR with Return |
+|        |          |       | DALOD GIRL <i>Return</i>      |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+|        |          |       | <i>Return</i>                 |
+
+**TOTAL PACKAGE WEIGHT**
+
+I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt.
+
+DATE \_\_\_\_\_ SIGNATURE \_\_\_\_\_ ID# \_\_\_\_\_ UNIT \_\_\_\_\_
+
+RECEIVED BY *AB 8338* REASON *6* DATE/TIME RECEIVED *10-20-05 1500 kg*

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marker2/court-doe-102-v-epstein/EFTA02738823/EFTA02738823.md

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+## Podhurst Orseck TRIAL & APPELLATE LAWYERS
+
+Aaron S. Podhurst Robert LLosefsberg Joel D. Steven C. Marks Victor M. S Jr. Katherine W. Ezell Stephen P. Rosenthal Ricardo M. Martinez-Cid Ramon A. Rasco Alexander T. Rundlet John Gravante, Carolina Maharblz
+
+Robert D. Critton, Jr., Esq. Bunnan Critton Luttier & Coleman 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401-2918
+
+Jack Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401
+
+May 15, 2009
+
+Robert Orseck (1934-1978)
+
+Re: Preservation of Evidence Relevant to Actions for Civil Remedies Pursuant to 18 U.S.C. §2255
+
+Gentlemen:
+
+Walter H. Bockhorn, Jr. Karen Podhurst Dem Of Counsel
+
+As you know, we represent a number of the young women on the list of names provided to Messrs. Goldberger and Tein by the U.S. Attorney's Office regarding the Jeffrey Epstein Non-Prosecution Agreement and Addendum. In order to bo crystal clear as to whom wo represent, we have attached a list of our present clients. By this letter, we want to ensure that discoverable information relating to each of their civil actions is being properly preserved, as is required under Rule 34 of the Federal Rules of Civil Procedure. You are required to take the neceqqaty steps to preserve all paper documents, tangible objects (including, but not limited to, film, videos, DVDs, photographs, whether in hard copy, negatives or digital images), and electronically stored information related to any threatened action by my clients, whether found inside or outside of the United States, including any information held by third parties. Although we may bring a motion %r an order preserving documents and other data from destruction or alteration, your client's obligation to preserve documents and other data discovery in this case arises independently from any order on such motion.
+
+As you know, the Non-Prosecution Agreement also requires your client "to maintain [his] evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, inviolate until all of the terms of
+
+![](_page_0_Picture_12.jpeg)
+
+this agreement have been satisfied." We will seek information related to Mr. Epstein's sexual exploitation of our clients in violation of 18 U.S.C. §§ 2421, 2422, 2423, 2251, 2252, and/or 2252A, all in violation of 18 U.S.C. § 2255. Your client reasonably should have known of potential criminal prosecution and/or civil litigation since, at least, October 25, 2005. This duty to preserve evidence extends to evidence beyond that which was seized from Mr. Epstein's residence on October 25, 2005. It also extends to evidence that was seized on October 25, 2005 and later returned to him if it may be relevant and discoverable in any of these civil actions.
+
+Because of the nature of these violations, we consider electronically stored information to be a critical and irreplaceable source of discovery and/or evidence in this matter. You should anticipate that much of the information subject to disclosure or responsive to discovery in this cause is stored on your current *and former* computer systems and other media and devices (including handheld devices, personal digital assistants, voice-messaging systems, online repositories and cell phones). Electronically stored information should be afforded the broadest possible meaning and includes (*by way of example and not as an exclusive list*) potentially relevant information electronically, magnetically, optically or otherwise stored as:
+
+1. 1. Digital communication (*e.g.*, e-mail, voice mail, instant messaging);
+2. 2. E-mail Server Stores (*e.g.*, Lotus Domino .NSF or Microsoft Exchange .EDB)
+3. 3. Word-processed documents (*e.g.*, Word or WordPerfect files and drafts);
+4. 4. Spreadsheets and tables (*e.g.*, Excel or Lotus 123 worksheets);
+5. 5. Accounting Application Data (*e.g.*, QuickBooks, Money, Peachtree data);
+6. 6. Image and Facsimile Files (*e.g.*, .PDF, .TIFF, .JPG, .GIF images);
+7. 7. Sound Recordings (*e.g.*, .WAV and .MP3 files);
+8. 8. Video and Animation (*e.g.*, .AVI and .MOV files);
+9. 9. Databases (*e.g.*, Access, Oracle, SQL Server data, SAP);
+10. 10. Contact and Relationship Management Data (*e.g.*, Outlook, ACTD);
+11. 11. Calendar and Diary Application Data (*e.g.*, Outlook PST, blog entries);
+12. 12. Online Access Data (*e.g.*, Temporary Internet Files, History, Cookies);
+13. 13. Presentations (*e.g.*, PowerPoint, Corel Presentations);
+14. 14. Network Access and Server Activity Logs;
+15. 15. Project Management Application Data;
+16. 16. Computer Aided Design/Drawing Files; and
+17. 17. Backup and archival files (*e.g.*, Veritas, Zip, .GHO).
+
+Electronically stored information resides not only in areas of electronic, magnetic, and optical storage media reasonably accessible to you and your client, but also in areas you may deem *not* reasonably accessible. You are obliged to preserve potentially relevant evidence from *both* sources of electronically stored information, even if you do not anticipate *producing* such electronically stored information. Similarly, you and your client are obligated to preserve all potentially relevant evidence even if you do not intend to produce such evidence because you anticipate raising your client's Fifth Amendment privilege against self-incrimination.
+
+The laws and rules prohibiting destruction of evidence apply to electronically stored information in the same manner that they apply to other evidence. Because of its format,
+
+electronically stored information is easily deleted, modified or corrupted. Accordingly, your client must take every reasonable step to preserve this information until the final resolution of this matter. Adequate preservation of electronically stored information requires more than simply refraining from efforts to destroy or dispose of such evidence. You must intervene to prevent lass due to routine operations or malfeasance and you must employ proper techniques and protocols to preserve electronically stored information. Booting a drive, examining its contents, or running any application may irretrievably alter the evidence it contains and constitute unlawful spoliation of evidence. Preservation requires preemptive immediate intervention.
+
+With regard to electronically stored information created subsequent to the date of delivery of this letter, relevant evidence should not be destroyed, and your client is to take appropriate steps required to avoid destruction of such evidence.
+
+Please forward a copy of this letter to all persons and entities with custodial responsibility for the evidence referred to in this letter.
+
+Failure to abide by this request could result in penalties and/or sanctions against your client and could form the basis of legal claims for spoliation.
+
+if this correspondence is in any way unclear, please contact us immediately. We look forward to receiving written confirmation from you that you have taken the necessary steps to fulfill these preservation obligations by Thursday, May 21, 2009 in order to alleviate the need for us to seek a court order.
+
+> Since , rely
+
+Robert.
+
+bert jose--da r. "----
+
+C.
+
+cc: Roy Black, Esq. Jay I.efkowitz, Esq.
+
+List of Clients Represented by Podhurst Orseck, P.A.,  
+as of May 15, 2009<sup>1</sup>
+
+[REDACTED]
+
+---
+
+<sup>1</sup> We will supplement this list as necessary.

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marker2/court-doe-102-v-epstein/EFTA02738827/EFTA02738827.md

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+## UNTIED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRAi
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA/
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5, CASE NO.: 08-CV-8038I-MARRA
+
+Plaintiff,
+
+VS.
+
+Defendant.
+
+JANE DOE NO. 6,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80994-MARRA/M.
+
+JANE DOE NO. 7, CASE NO.: 08-CV-80993-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+C.M.A., CASE NO.: 08-CV-80811-MARRA/JOHNSON
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08-CV-80893-MARRA
+
+Plaintiff,
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. II, CASE NO.: 08-CV-80469-MARRAI
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 102, CASE NO.: 09-CV-80656-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## ORDER
+
+THIS CAUSE comes before the Court on Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for an Order for the Preservation of Evidence and Incorporated Memorandum of
+
+Law (DE #j, filed May 26, 2009. Plaintiffs represent that Defendant has not agreed to the relief requested in this motion. The Court has carefully considered the motion and is otherwise fully advised in the premises.
+
+It is ORDERED AND ADJUGED that Plaintiffs' Motion (DE # J is GRANTED.
+
+A. Defendant, Jeffrey Epstein, and his employees, his agents, his attorneys, and other nonparties are directed to take every reasonable step to preserve all evidence, including, but not limited to, evidence related to the October 25 search, documents, data, and tangible things, which includes, but is not limited to, writings; records; files; correspondence; digital or chemical process photographs (including negatives); reports; memoranda; calendars; diaries; minutes; electronic messages; voicemail; email; telephone message records or logs; computer and network activity logs; hard drives; backup data; removable computer storage media, such as tapes, disks, and cards; printouts; document image files; web pages; databases; spreadsheets; software; books; ledgers; journals; orders; invoices; bills; vouchers; checks; statements; worksheets; summaries; compilations; computations; charts; diagrams; graphic presentations; drawings; films; charts; video, phonographic, tape, or digital recordings or transcripts thereof; drafts; jottings; and notes. Information that serves to identify, locate, or link such material, such as file inventories, file folders, indices, and metadata, is also included. Specifically, Defendant must preserve the following evidence: records of phone communications; records of domestic and international travel, including travel in Defendant's private airplanes; former and current employee records; tax returns; medical bills; bills regarding any other expenses; all documents evidencing payment by Defendant of U.S. currency and/or merchandise to each victim; any evidence stored in Defendant's storage unit; photos of Defendant's
+
+mansions; any diary, log, memo pad, calendar, or other writing reflecting date of each victim's visit(s) to Defendant's mansions; any diary or document wherein each victim wrote regarding a victim's visit to Defendant's mansions; all documents sent to or by the PBPD, the FBI, the USAO, or the PBSAO; and all computers used by Defendant and/or his agents and/or employees since 1998.
+
+- B. The duty extends to documents, data, and tangible things in the possession, custody, and/or control of the parties to this action and any employees, agents, contractors, carriers, bailees, or other nonparties who possess materials reasonably anticipated to be subject to discovery in these actions. Counsel is under an obligation to exercise reasonable efforts to identify and notify such nonparties.
+- C. "Preservation" is to be interpreted broadly to accomplish the goal of maintaining the integrity of all documents, data, and tangible things reasonably anticipated to be subject to discovery in these actions under Rules 26, 45, and 56(e) of the Federal Rules of Civil Procedure. Preservation includes taking reasonable steps to prevent the partial or full destruction, alteration, testing, deletion, shredding, incineration, wiping, relocation, migration, theft, or mutation of such material, as well as negligent or intentional handling that would make material incomplete or inaccessible.
+- D. Defendant, Jeffrey Epstein, and his employees, agents, and attorneys shall preserve any evidence from the October 25, 2005 execution of a search warrant at his mansion at 358 El Brillo Way in Palm Beach, Florida, that has already been returned to him by the Palm Beach Police Department.
+- E. If an objection or privilege is raised, the parties may raise the issue with this Court and shall preserve the evidence in question pending resolution by the Court.
+
+F. The parties, without leave of Court, may agree in writing that certain documents or categories of evidence need not be preserved as otherwise required by this Order. If such agreement is reached, such agreement is effective upon signing and without further order of this Court.
+
+G. This Order shall not be deemed to create any "safe harbors" for the destruction of evidence. If this Court determines that evidence has been destroyed or lost, whether knowingly or not, it will impose appropriate sanctions.
+
+H. Each party shall bear its own costs for complying with this Order.
+
+DONE AND ORDERED in at West Palm Beach, Palm Beach County, Florida, this of , 2009.
+
+> KENNETH A. MARRA United States District Court Judge
+
+Copies to: All counsel of record

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marker2/court-doe-102-v-epstein/EFTA02738833/EFTA02738833.md

@@ -0,0 +1,336 @@
+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2,
+
+Plaintiff;
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80119-MARRA=M
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA I
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARRA
+
+Plaintiff
+
+vs.
+
+Defendant.
+
+JANE DOE NO. 6,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80994-MARRA/Mil
+
+/
+
+JANE DOE NO. 7, CASE NO.: 08-CV-80993-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+C.M.A., CASE NO.: 08-CV-80811-
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08-CV-80893-MARRA
+
+Plaintiff,
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. II,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80469-MARRA/
+
+JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARRAi
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant
+
+/
+
+JANE DOE NO. 102, CASE NO.: 09-CV-80656-MARRABOHNSON
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+PLAINTIFFS JANE DOE NO. 101 AND JANE DOE NO. 102's MOTION FOR AN ORDER FOR THE PRESERVATION OF EVIDENCE AND INCORPORATED MEMORANDUM OF LAW
+
+Plaintiffs, Jane Doe No. 101 and Jane Doe No. 102 (the "Plaintiffs"), pursuant to Rules 26, 34, and 37 of the Federal Rules of Civil Procedure, hereby move this Court for an Order for the Preservation of Evidence directed to Defendant, Jeffrey Epstein, and, as grounds, state as follows:
+
+1. After investigations by the Palm Beach Police Department ("PBPD"), the Palm Beach State Attorney's Office ("PBSAO"), the Federal Bureau of Investigation ("FBI"), and the United States Attorney's Office for the Southern District of Florida ("USAO"), Defendant, Jeffrey Epstein, in June 2008, entered pleas of "guilty" in the Fifteenth Judicial Circuit in Palm Beach County, Florida, to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution.
+
+2. As outlined in detail in the relevant complaints, 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. Defendant, Jeffrey Epstein, sexually abused Plaintiffs while Plaintiffs were under the age of 18 years old.
+
+3. As a result of Defendant's sexual abuse, Plaintiffs filed their actions, alleging multiple violations 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. § 2421, § 2422(a), § 2422(b), § 2423(a), § 2423(b), § 2423(e), § 2251, § 2252, § 2252A(a)(1), and § 2252A(g)(1).
+
+4. On October 25, 2005, the PBPD executed a search warrant at Defendant's Palm Beach, Florida mansion at 358 El Brillo Way. Thus, Defendant reasonably should have known of potential criminal prosecution and/or civil litigation since at least that date.
+
+5. According to the PBPD Property Receipt, evidence seized during the October 25, 2005 search included phone message books, photographs of nude underage females, VHS tapes, CDs, and school transcripts of underage girls. See PBPD Property Receipt (attached hereto as Exhibit A). While still incarcerated, Defendant filed a Motion for Return of Property with the Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County on July 23, 2008. On September 5, 2008, this Court entered an Order in Jane Doe v. Jeffrey Epstein, et at, Case No. 08-80804-CIV-MARRa directing Defendant to preserve the evidence listed in the PBPD Property Receipt and to provide duplicates to the plaintiff should this evidence be returned to Defendant by the State of Florida (DE# 20).
+
+6. According to the PBPD Property Receipt, at least some of the evidence has already been returned to Defendant, including zip CDs, 8mm videotapes, floppy disks, zip drive disks, CPUs from various areas throughout the mansion, and phone message books. Upon information and belief, one or more sexually explicit printed photographs of Plaintiffs and other minor girls taken by Defendant and/or his agents when Plaintiffs were minors were confiscated during the search and may have been returned to him. In addition, the zip CDs, 8mm videotapes, floppy disks, zip drive disks, and CPUs that were returned to Defendant may have contained, and may still contain, pornographic images of these and other minors. Plaintiffs respectfully request that this Court clarify that the Order of September 5, 2008 requires returned evidence to be preserved.
+
+7. In addition, Plaintiffs respectfully request this Court to take judicial notice that, in the event that such evidence includes child pornography, it is imperative for the PBPD, the FBI,
+
+the USAO, and the PBSAO not to return any photographs that may be child pornography (including files, electronic or otherwise) to Defendant or his counsel. Pursuant to the Adam Walsh Protection and Safety Act, Pub. L. No. 109-248, 120 Stat. 587 (2006), any property or material that constitutes child pornography shall remain in the care, custody, and control of either the government or the court. Defendant has no right to seek its return. See 18 U.S.C. § 3509(m) (2008). In addition, copying evidence that constitutes child pornography is not permissible as long as the Government makes the property or material reasonably available to the defendant. See 18 U.S.C. § 3509(mX2XA) (2008).
+
+8. In addition to evidence related to the October 25 search, Defendant, Jeffrey Epstein, exercises sole custody and control over specific evidence relevant and material to this lawsuit relating to Defendant's sexual abuse of Plaintiffs, including, but not limited to, documents, data, and tangible things, including, but not limited to, writings; records; files; correspondence; digital or chemical process photographs (including negatives); reports; memoranda; calendars; diaries; minutes; electronic messages; voicemail; e-mail; telephone message records or logs; computer and network activity logs; hard drives; backup data; removable computer storage media, such as tapes, disks, and cards; printouts; document image files; web pages; databases; spreadsheets; software; books; ledgers; journals; orders; invoices; bills; vouchers; checks; statements; worksheets; summaries; compilations; computations; charts; diagrams; graphic presentations; drawings; films; charts; video, phonographic, tape, or digital recordings or transcripts thereof; drafts; jottings; and notes. Information that serves to identify, locate, or link such material, such as file inventories, file folders, indices, and metadata, is also included. Specifically, Plaintiffs consider the following evidence relevant: records of phone communications; records of domestic and international travel, including travel in Defendant's private airplanes; former and current employee records; tax returns; medical bills; bills regarding any other expenses; all documents evidencing payment by Defendant of U.S. currency and/or merchandise to each victim; any evidence stored in Defendant's storage unit; photographs of Defendant's mansions; any diary, log, memo pad, calendar, or other writing reflecting date of each victim's visit(s) to Defendant's mansions; any diary or document wherein each victim wrote regarding a victim's visit to Defendant's mansions; all documents sent to or by the PBPD, the FBI, the USAO, or the PBSAO; and all computers used by Defendant and/or his agents and/or employees since 1998.
+
+9. Other relevant evidence includes, but is not limited to, electronically-stored information stored on Defendant's current and former computer systems and other media and devices (including handheld devices, personal digital assistants, voice-messaging systems, online repositories, and cellular telephones). Electronically-stored information should be afforded the broadest possible meaning and includes (by way of example and not as an exclusive list) potentially relevant information electronically, magnetically, optically, or otherwise stored as:
+
+- 1. Digital communication (e.g., e-mail, voice mail, instant messaging);
+- 2. E-mail Server Stores (e.g., Lotus Domino .NSF and Microsoft Exchange .EDB)
+- 3. Word-processed documents (e.g., Word and WordPerfect files and drafts);
+- 4. Spreadsheets and tables (e.g., Excel or Lotus 123 worksheets);
+- 5. Accounting Application Data (e.g., QuickBooks, Money, Peachtree data);
+- 6. Image and Facsimile Files (e.g., .PDF, .TIFF, JPG, .GIF images);
+- 7. Sound Recordings (e.g., .WAV and .MP3 files);
+- 8. Video and Animation (e.g., .AVI and .MOV files);
+- 9. Databases (e.g., Aerns, Oracle, SQL Server data, SAP);
+- 10. Contact and Relationship Management Data (e.g., Outlook, ACTI);
+- 11. Calendar and Diary Application Data (e.g., Outlook PST, blog entries);
+- 12. Online Access Data (e.g., Temporary Internet Files, History, Cookies);
+- 13. Presentations (e.g., PowerPoint, Corel Presentations);
+- 14. Network Access and Server Activity Logs; IS. Project Management Application Data;
+- 16. Computer Aided Design/Drawing Files; and
+- 17. Backup and archival files (e.g., Veritas, Zip, .G11O).
+
+10. Plaintiffs also respectfully request this Court to order Defendant to preserve all potentially relevant evidence, even if Defendant does not intend to produce such evidence because he anticipates raising his Fifth Amendment privilege against self-incrimination.
+
+11. As more fully set forth in Plaintiff Jane Doe No. 102's Complaint (DE # 1 in Case No.: 09-CV-80656-MARRS), Defendant is a designated sexual offender who sexually exploited minor girls all over the world, including in some or all of his six mansions. Thus, there is reason to believe that relevant evidence, including many photographs of other nude underage females, exists in some or all of Defendant's six mansions, with all but one of his mansions located outside the State of Florida.
+
+12. On May 15, 2009, Plaintiff's counsel sent a letter to Defendant's counsel detailing the numerous sources of relevant evidence in this matter (the "Preservation Letter," attached hereto as Exhibit B). Despite requests for a written response confirming Defendant's duty to take the nes-awry steps to preserve all relevant evidence, Defendant and his counsel have neither acknowledged this letter nor confirmed their duty to preserve all relevant evidence under the Federal Rules of Civil Procedure.
+
+13. In the past, Defendant's counsel have asserted that a motion requesting to preserve evidence would be moot because of an order previously entered in Jane Doe v. Jeffrey Epstein, et at, Case No. 08-80804-CIV-MARRa. Plaintiffs respectfully submit that an enforceable order is needed in their particular cases and that the binding order needs to cover evidence other than evidence related to the October 25, 2005 search of Defendant's Palm Beach mansion. The sole focus of the previous order is seized evidence identified in the PBPD Property Receipt. There is great need to preserve all evidence (physical and electronic), especially with respect to potential evidence related to Defendant's possession, production, and/or transportation of child pornography. In addition, there is reason to believe that relevant
+
+evidence, including many photographs of other nude minor girls, exist in some or all of Defendant's six mansions and/or on some or all of his computers. Given Defendant's efforts to gain control over evidence in the custody of the PBPD, as well as Defendant's unwillingness to acknowledge or respond to Plaintiff's Preservation Letter, a legitimate concern remains for the continuing existence and maintenance of the integrity of the evidence in question absent an order preserving the evidence. This evidence, some of which is in the sole custody, dominion, and control of Defendant, is critical and indispensable to Plaintiffs' cases.
+
+# Memorandum of Law
+
+When there is a good faith belief that evidence may be lost, the Court has the authority to enter an order preserving such evidence. See AT & T Mobility LLC v. Dynamic Cellular Corp., No. 08-20537-Civ., 2008 WL 2139518, at \*2 (S.D. Fla. May 7, 2008); see also Tracfone Wireless, Inc. v. Trading, Inc., No. 3-08-CV-0398-B, 2008 WL 918243, at \*1 (N.D. Tex. Mar. 13, 2008) (finding "a legitimate concern for the continuing existence and maintenance of the integrity of the evidence in question absent an order preserving the evidence"). This evidence, some of which is in the sole custody, dominion, and control of Defendant, is critical and indispensable to Plaintiffs' cases. The evidence that Plaintiffs seek to protect is relevant and critical to the prosecution not only of their actions, but for the prosecution of at least ten other filed actions against Defendant and twenty-two other as-yet-unfiled actions by Defendant's victims listed on the USAO List. Plaintiffs' concerns outweigh any harm to Defendant that may result from a preservation order. Given Defendant's vast wealth and demonstrated willingness to incur expenses, Defendant will not be unduly burdened by such an order. See Tracfone Wireless, Inc., 2008 WL 918243, at \*1.
+
+Defendant, Jeffrey Epstein, is a designated sexual offender who was convicted of violating various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution, and is currently serving his sentence based on the charges that form the foundation of Plaintiffs' claims. Therefore, it is reasonable to assume that both the evidence seized by the PBPD and other relevant evidence in Defendant's custody and control is extremely harmful to Defendant's position in his civil cases. Defendant's successful efforts to obtain the return of some of the seized property causes Plaintiffs grave concern regarding his willingness to comply with his duty to preserve all evidence relevant to Plaintiffs' actions. Without a protective order, Defendant, Jeffrey Epstein, may seek to destroy records and information to thwart this lawsuit and many other lawsuits and thus perpetuate the wrongs that the federal laws regarding the sexual exploitation of children intend to protect.
+
+Because of the nature of the relevant violations, which include allegations of production and transportation of child pornography, electronically-stored information is a valuable and irreplaceable source of discovery and/or evidence in these matters. Plaintiffs anticipate that much of the information subject to disclosure or responsive to discovery in this cause is stored on Defendant's former computer systems and other media and devices. In addition, as previously stated, Plaintiffs believe that crucial relevant evidence may be present in some or all of the computers in perhaps each of his six mansions (in Palm Beach, New York City, Santa Fe, London, Paris, and the U.S. Virgin Islands).
+
+Finally, in the other pending Jane Doe cases with active discovery, Defendant, Jeffrey Epstein, has objected to the production of any evidence on Fifth, Sixth, and Fourteenth Amendment grounds. Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 challenge Defendant's objections to discovery and, more relevant to the matter at hand, request that this Court issue an order clearly stating that Defendant has a duty to preserve all relevant evidence, regardless of whether he intends to raise his privilege against self-incrimination. See Capricorn Power Co. v. Siemens Westinghouse Power Corp., 220 F.R.D. 429, 434 (W.D. Pa. 2004) (A motion for a preservation order can be granted with regard to all items of evidence that are discoverable in accordance with the Federal Rules of Civil Procedure, without the necessity of establishing that the evidence will necessarily be relevant and admissible at trial.)
+
+WHEREFORE, in light of the above-stated duty to preserve all relevant evidence, Plaintiffs, Jane Doe No. 101 and Jane Doe No. 102, move this Court to enter an Order granting Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for the Preservation of Evidence.
+
+## CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1A-3
+
+Undersigned counsel conferred with counsel for Defendant in a good faith effort to resolve the issues raised in this motion. Despite requests for a written response acknowledging Defendant's duty to take the necessary steps to preserve all relevant evidence to alleviate the need for this motion, Defendant's counsel have failed to respond or acknowledge in any way Defendant's duty to preserve all relevant evidence under the Federal Rules of Civil Procedure. Date: May 26, 2009
+
+> s/Robert C. Josefsberg Robert C. Josefsberg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. City National Bank Building 25 West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) rjosefsberg@podhurst.com kezell©podhurst.com
+
+Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+### Certificate of Service
+
+I hereby certify that, on May 26, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. 1 also certify that the foregoing document is being served this day on all counsel of record identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+> A/ Robert Josefsberg Robert C. Josefsberg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. City National Bank Building 25 West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) riosefsbergOpodhurst.com kezell©podhurst.com
+
+Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+### SERVICE LIST
+
+JANE DOE NO. 2 v. JEFFREY EPSTEIN
+
+Case No. 08-CV-80119-MARRa
+
+United States District Court, Southern District of Florida
+
+Robert Critton, Esq.
+
+Michael J. Pike, Esq.
+
+Burman, Critton, Luther & Coleman LLP
+
+515 North Flagler Drive, Suite 400
+
+West Palm Beach, FL 33401
+
+Phone: (561) 842-2820
+
+Fax: (561) 515-3148
+
+rcrit@bc1claw.com
+
+mpike@bciclaw.com
+
+Counsel for Defendant, Jeffrey Epstein
+
+Jack Goldberger, Esq.
+
+Atterbury, Goldberger & Weiss, P.A.
+
+250 Australian Avenue South, Suite 1400
+
+West Palm Beach, FL 33401
+
+Phone: (561) 659-8300
+
+Fax: (561) 835-8691
+
+jaaesoabellsouth.net
+
+Co-Counsel for Defendant, Jeffrey Epstein
+
+Bruce E. Reinhart, Esq.
+
+Bruce E. Reinhart, P.A.
+
+250 South Australian Avenue, Suite 1400
+
+West Palm Beach, FL 33401
+
+Phone: (561) 202-6360
+
+Fax: (561) 828-0983
+
+ecfRbrucereinhartlaw.com
+
+Counsel for Co-Defendant,
+
+Jack Scarola, Esq.
+
+Jack P. In 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@scarcvlaw.com
+
+inh@searcylaw.com
+
+Counsel for Plaintiff C.M.44.
+
+Adam Horowitz, Esq.  
+Stuart Mermelstein, Esq.  
+Mermelstein & Horowitz, P.A.  
+18205 Biscayne Blvd., Suite 2218  
+Miami, FL 33160  
+Phone: (305) 931-2200  
+Fax: (305) 931-0877  
+[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com)  
+[smermelstein@sexabuseattorney.com](mailto:smermelstein@sexabuseattorney.com)  
+*Counsel for Plaintiffs in Related Case Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994*
+
+Spencer Todd Kuvin, Esq.  
+Theodore Jon Leopold, Esq.  
+Leopold Kuvin, P.A.  
+2925 PGA Boulevard, Suite 200  
+Palm Beach Gardens, FL 33410  
+Phone: (561) 515-1400  
+Fax: (561) 515-1401  
+[skuvin@leopoldkuvin.com](mailto:skuvin@leopoldkuvin.com)  
+[tleopold@leopoldkuvin.com](mailto:tleopold@leopoldkuvin.com)  
+*Counsel for Plaintiff in Related Case No. 08-08804*
+
+Richard Willits, Esq.  
+Richard H. Willits, P.A.  
+2290 10<sup>th</sup> Ave North, Suite 404  
+Lake Worth, FL 33461  
+Phone: (561) 582-7600  
+Fax: (561) 588-8819  
+[lawyerwillits@aol.com](mailto:lawyerwillits@aol.com)  
+[reelrhw@hotmail.com](mailto:reelrhw@hotmail.com)  
+*Counsel for Plaintiff in Related Case No. 08-80811*
+
+Brad [REDACTED], Esq.  
+Law Office of Brad [REDACTED] & Associates, LLC  
+2028 [REDACTED] Street, Suite 202  
+Hollywood, FL 33020  
+Phone: (954) 414-8033  
+Fax: (954) 924-1530  
+[bedwards@rra-law.com](mailto:bedwards@rra-law.com)  
+[be@bradedwardslaw.com](mailto:be@bradedwardslaw.com)  
+*Counsel for Plaintiff in Related Case No. 08-80893*
+
+Isidro Manuel MB Esq.
+
+Elkins & Boehringer
+
+224 Datura Avenue, Suite 900
+
+West Palm Beach, FL 33401
+
+Phone: (561) 832-8033
+
+Fax: (561) 832-7137
+
+isidrogarcia(dbellsouth.net
+
+Counsel for Plaintiff in Related Case No. 08-80469

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marker2/court-doe-102-v-epstein/EFTA02738848/EFTA02738848.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5, CASE NO.: 08-CV-8038I-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRA
+
+vs.
+
+JEFFREY EPSTEIN.
+
+Defendant.
+
+JANE DOE NO. 7, CASE NO.: 08- CV-80993-MARRA,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+J
+
+C.M.A., CASE NO.: 08- CV-80811 -MARIZA/
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08- CV-80893-MARIZA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, et al.,
+
+Defendant.
+
+DOE II, CASE NO.: 08-CV- 80469-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN et al.,
+
+Defendant.
+
+JANE DOE NO. 101, CASE NO.: 08- CV-80591-MARRA.
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant. /
+
+JANE DOE NO. 102, CASE NO.: 08- CV-80656-MARRA,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant. /
+
+## ORDER
+
+Upon Plaintiffs' Motion for Enlargement of Time to Respond to Defendant's Motion to Compel and/or Identify Jane Doe in the Style of this Case and Motion to Identify Jane Doe in Third Party Subpoenas for Purposes of Discovery, or Alternatively Motion to Dismiss Sua Sponte, and good cause being shown, it is hereby
+
+ORDERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of time of twenty (20) days until June I I, 2009, to respond to the Defendant's Motions to Compel and/or Identify Jane Doe in the Style, a at.
+
+DONE AND ORDERED in , at West Palm Beach, Palm Beach County, Florida, this day of 2009.
+
+DISTRICT COURT JUDGE

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marker2/court-doe-102-v-epstein/EFTA02738851/EFTA02738851.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5, CASE NO.: 08-CV-8038I-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRAM=
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 7,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+C.M.A., CASE NO.: 08- CV-80811 -MARRA,I l
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08- CV-80893-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN, et al.,
+
+Defendant.
+
+CASE NO.: 08- CV-80993-MARRA
+
+DOE II, CASE NO.: 08-CV- 80469-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN et al., Defendant.
+
+/
+
+JANE DOE NO. 101, CASE NO.: 08- CV-80591-MARRA.
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN, Defendant. /
+
+JANE DOE NO. 102, CASE NO.: 08- CV-80656-MARRa
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN, Defendant. /
+
+## NOTICE OF FILING PROPOSED ORDER
+
+Plaintiffs, Jane Does 2-7, by and through their undersigned counsel, hereby file the attached Proposed Order in reference to document no. III filed in case no. 08-80119 on May 21, 2009.
+
+Dated: May 27, 2009 Respectfully submitted,
+
+By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) ssm@sexabuseattomey.com Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattorney.com MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218
+
+Miami, Florida 33160
+
+Tel: (305) 931-2200
+
+Fax: (305) 931-0877
+
+## CERTIFICATE OF SERVICE
+
+I hereby certify that on May 27, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+/s/ Adam D. Horowitz
+
+## SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida
+
+Jack Alan Goldberger, Esq. igoldberger@agwpa.com
+
+Robert D. Critton, Esq. rcritton@bc1claw.com
+
+James bedwards@rra-law.com
+
+Isidro Manuel isidrogarcia@bellsouth.net
+
+Jack iah@searcvlaw.com Katherine Warthen Ezell KEzell@podhurst.com
+
+Michael James Pike MPike@bciclaw.com
+
+Paul G. Cassell cassellp@law.utah.edu
+
+Richard Horace Willits lawyerwillits@aol.com
+
+Robert C. Josefsberg rjosefsberg@podhurst.com
+
+/s/ Adam D. Horowitz

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marker2/court-doe-102-v-epstein/EFTA02738857/EFTA02738857.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA I
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+/
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+/
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+/
+
+JANE DOE NO. 5, CASE NO.: 08-CV-8038I-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+JANE DOE NO. 7, CASE NO.: 08-CV-80993-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+C.M.A., Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+JANE DOE, Plaintiff,
+
+VS.
+
+JEFFREY EPSTEIN et al, Defendants.
+
+CASE NO.: 08-CV-80811-MARRA
+
+J
+
+CASE NO.: 08-CV-80893-MARRA
+
+DOE IL Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN et al, Defendants.
+
+CASE NO.: 09-CV-80469-MARRa
+
+JANE DOE NO. 101, CASE NO.: 09-CV-8059 I -MARRA/
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+JANE DOE NO. 102 CASE NO.: 09-CV-80656-MARRia
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+## UNITED STATES' NOTICE OF LIMITED APPEARANCE AS AMICUS CURIAE TO FILE RESPONSE TO COURT'S ORDER REOUESTING POSITION ON DEFENDANT'S MOTION TO STAY IDE 991
+
+Comes now the United States, by and through the undersigned Assistant United States Attorney, and makes this limited appearance to file via CM/ECF its response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. By filing this notice of limited appearance and its response, the United States does not make itself a party to this litigation and takes no position with respect
+
+to the outcome of any of the civil suits. By filing this notice of limited appearance and response, the United States also does not waive any procedural or statutory bars to suit.
+
+Respectfully submitted,
+
+R. ALEXANDER ACOSTA UNITED STATES ATTORNEY
+
+By: s/A. Villa aiia A. VILLAFANA Assistant United States Attorney Florida Bar No. 0018255 500 East Broward Boulevard, 7th Floor Ft. Lauderdale, FL 33394 Telephone: 954-356-7255 Facsimile: 954-356-7230
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that on May 28, 2009, 1 electronically filed the foregoing document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties are able to receive notice via the CM/ECF system.
+
+> s/A. Villa aiia A. VILLAFARA Assistant United States Attorney

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marker2/court-doe-102-v-epstein/EFTA02738861/EFTA02738861.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+/
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+/
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+/
+
+JANE DOE NO. 5, CASE NO.: 08-CV-8038I-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+JANE DOE NO. 7, CASE NO.: 08-CV-80993-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+C.M.A., Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+JANE DOE, Plaintiff,
+
+VS.
+
+JEFFREY EPSTEIN et al, Defendants.
+
+CASE NO.: 08-CV-80811-MARRA
+
+J
+
+CASE NO.: 08-CV-80893-MARRA
+
+DOE II, Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN et al, Defendants.
+
+CASE NO.: 09-CV-80469-MARRa
+
+JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARRA/JOHNSON
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+JANE DOE NO. 102 CASE NO.: 09-CV-80656-MARRA,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+### UNITED STATES' RESPONSE TO COURT'S ORDER REQUESTING POSITION ON DEFENDANT'S MOTION TO STAY IDE 991
+
+Comes now the United States, by and through the undersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessary and was not contemplated by the Non-Prosecution Agreement between the United States and Defendant Jeffrey Epstein.
+
+## ISSUE PRESENTED
+
+The United States is not a party to these lawsuits and, accordingly, is not fully aware of the scope of the proceedings, the range of arguments presented by counsel, and any correspondence or oral communications between the parties in these civil suits. Based on the information presented by the Court and a review of Defendant Jeffrey Epstein's Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law (Court File No. 08-CV-80811- MARRA/JOHNSON DE 51-1), and responses thereto filed by various plaintiffs in their suits, the undersigned understands that the Court has requested the position of the United States on the following issue:
+
+Are there "special circumstances" that require the imposition of a stay of the civil proceedings in the "interests of justice" until the "expiration" of the Non-Prosecution Agreement ["NPA"] between the United States and Epstein?
+
+By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of any of the civil suits; nor does the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the NPA. The United States also declines to comment on Defendant Epstein's representations regarding past allegations of violations of the NPA by Epstein. The United States files this response solely as amicus curiae at the Court's request and does not waive any procedural or statutory bars to suit.
+
+# I. STANDARD FOR IMPOSING A DISCRETIONARY STAY
+
+### A. The Defendant Must Show that the Assertion of His Fifth Amendment Privilege Against Self-Incrimination Would Automatically Result in the Entry of Summary Judgment Against Him.
+
+"The decision whether or not to stay civil litigation in deference to parallel criminal proceedings is discretionary.... A movant must carry a heavy burden to succeed in such an endeavor." Microfinancial, Inc. v. Premier Holidays Interne', Inc., 385 F.3d 72, 77 (1st Cir. 2004) (citations omitted). When a defendant facing possible criminal liability invokes his Fifth Amendment right against compelled self-incrimination in connection with civil litigation, a court can stay discovery or the entire civil case. v. Jenne, 2007 WL 624286 \*1 (S.D. Fl. Feb. 23, 2007) (Cooke, J.). "However, `the Constitution does not require a stay of civil proceedings pending the outcome of related criminal proceedings. Forcing an individual to risk non-criminal disadvantage by remaining silent for fear of self incrimination in a parallel criminal proceeding does not rise to the level of an unconstitutional infringement?" Id. (quoting Shell Oil Co. v. Altina Assocs., Inc., 866 F. Supp. 536, 540 (M.D. Fl. 1994)).
+
+As this Court has previously explained:
+
+The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United States v. Lot 5, Fox Grove, Alachua County, Fla, 23 F.3d 359, 363- 65 (11th Cir. 1994) ("Lot 5"), the Court articulated the following principles of law with respect to a stay of a civil action pending resolution of a related criminal action:
+
+[A] blanket assertion of the privilege is an inadequate basis for the issuance of a stay. Rather, a court must stay a civil
+
+proceeding pending resolution of a related criminal prosecution only when "special circumstances" so require in the "interests of justice." The court may deny a stay so long as the privilege's invocation does not compel an adverse judgment against the claimant.
+
+[T]he standard set by the Eleventh Circuit as to when a stay should be granted to prevent unconstitutional infringement is more narrow. The law in the Eleventh Circuit requires consideration of whether, as a result of invoking the privilege, the defendant faces certain loss of the civil proceeding on summary judgment if the civil proceeding were to continue. Lot 5, 23 F.3d at 364; Pervis v. State Farm Fire & Casualty Co., 901 F.2d 944 (1 1 th Cir. 1990). Under this standard, Movants must show that invocation of the privilege in the instant matter will result in certain loss by automatic summary judgment. United States v. Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most 'effective defense.' Securities & Exchange Comm. v. lncendy, 936 F. Supp. at 955 (S.D. H. 1996); Shell Oil Ca, 866 F. Supp. at 540-41.
+
+Court-Appointed Receiver of Lancer Mgt. Group LLC v. Lauer, 2009 WL 800144 (S.D. Fl. Mar. 25, 2009) (Marra, J.).
+
+Thus, before reaching the relative benefit and prejudice to each of the parties caused by staying the cases, the Court must determine whether, if defendant Epstein were to invoke his Fifth Amendment right against self-incrimination' and the Court were to allow an adverse inference to be drawn therefrom, an adverse judgment against Epstein would be automatically compelled. The United States respectfully submits that it would not.
+
+<sup>&#</sup>x27;It appears from a brief review of some of Epstein's discovery responses that Epstein has made a blanket assertion of the privilege. For example, Epstein has asserted his Fifth Amendment privilege in response to a plaintiff's request to produce the NPA and the United States' list of identified victims although these documents were provided to Epstein by the United States.
+
+From a review of the Complaints filed by the plaintiffs in these cases, it appears that some have filed claims based upon Title 18, United States Code, Section 2255, some have filed claims based upon common law torts, and some have filed a combination of the two. Under general principles of tort law, a plaintiff is required to prove: (1) that the defendant committed a bad act; (2) that the plaintiff suffered damages; and (3) that the damages were caused by the defendant's bad act. To succeed on a claim under 18 U.S.C. § 2255, a plaintiff must show: (I) that the plaintiff is a person who, while a minor, was a victim of an enumerated offense committed by the defendant; (2) that the person suffered personal injury as a result of that violation; and (3) the amount of damages she sustained.
+
+Epstein's assertion of his Fifth Amendment privilege could result in the drawing of a negative inference only as to the first element under both of these claims. Therefore, to succeed on summary judgment (or at trial), the plaintiffs would still have to prove that they suffered personal injury/damages as a result of the defendant's bad act. Cf. In re Financial Federated Title & Trust, Inc., 252 B.R. 834, 838 (S.D. Fl. Bank. Ct. 2000) (Stay not warranted in bankruptcy proceeding where criminal indictment was pending because negative inference related only to defendant's receipt of allegedly fraudulent transfers, but "Trustee must still carry the burden of proving all of the elements of his complaint for fraudulent transfers . includ[ing] fraudulent intent, insolvency, and financial condition at the time of the transfers to the Defendants.").
+
+While Epstein may believe that his arguments and proof as to the first element are his "most effective defense," that alone is insufficient to warrant the imposition of a stay of the
+
+litigation. There are two other items for the Court to consider in deciding this issue. First, pursuant to the terms of the NPA, as to those victims identified by the United States, Epstein has already made a concession that they are victims of an enumerated offense committed by Epstein. Thus, this inference is drawn not due to his invocation of the right against selfincrimination but due to his entry into a contractual agreement with the United States for which the identified victims are third-party beneficiaries.' Second, in Lot 5, the Eleventh Circuit pointed out the wealth of evidence other than the defendant's testimony that could be used to defeat a liability claim. See Lot 5, 23 F.3d at 364 ("Thus, Claimant's assertion that only her own testimony could vindicate her is groundless; other participants to the illegal acts that gave rise to the forfeiture were available to testify at trial. Claimant's failure to indicate with precision why she did not use other parties' testimony to substantiate her defense was fatal."). For example, Epstein could mount a defense using effective cross-examination, telephone records, travel records, documents within the possession of the plaintiffs or third parties, and/or the testimony of third parties to rebut the plaintiffs' proof.
+
+<sup>&#</sup>x27;The United States notes that it is not aware of the identities of all of the plaintiffs in the civil suits. To the extent that any are not &quot;identified victims&quot; under the NPA, this contractual provision would not apply.</p><h3>B. Additional Factors to Consider in Balancing the Prejudice to the Parties</h3><p block-type='Text'>If the Court is persuaded that the negative inference drawn from Epstein&#x27;s assertion of his Fifth Amendment privilege would result in an automatic grant of summary judgment in favor of the plaintiffs, then the Court must engage in a balancing of equities in determining whether there are &quot;special circumstances&quot; warranting the imposition of a stay &quot;&#x27;to prevent a party from suffering substantial and irreparable prejudice.&quot; Securites and Exchange Comm&#x27;n v. Incendy, 936 F. Supp. 952, 956 (S.D. FL 1996) (quoting S.E.C. v. First Financial Group of Texas, Inc., 659 F.2d 660, 668 (5th Cir. 1981) (add&#x27;/ citations omitted).</p><p block-type='Text'>Examples of &quot;special circumstances&quot; provided by the Supreme Court in [United States v. Kordel] are: (1) if the Government brought the civil action solely to obtain evidence for its criminal prosecution, (2) if the Government failed to advise the defendant in the civil proceeding that it contemplates his criminal prosecution; (3) if the defendant is without counsel or reasonably fears prejudice from adverse pretrial publicity or other unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety.</p><p block-type='Text'>Incendy at 956 (citing United States v. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Comm&#x27;n v.=, 261 Fed. Appx. 259, 263 (11th Cir. 2008) (&quot;[N]o &#x27;special circumstances&#x27; existed in this case warranting a stay, as there is no record evidence suggesting the Government had brought the civil case solely to obtain evidence for the criminal prosecution or that the criminal case against [defendant] was unconstitutional or inappropriately instituted.&quot;).</p><p block-type='Text' class='has-continuation'>No &quot;special circumstances&quot; exist here. First, unlike and Incendy, the United States Government is not a party to the civil litigation. Each suit is brought on behalf of an</p><p block-type='Text'>individual plaintiff represented by private counsel. Some of those plaintiffs are adverse to the United States and have filed suit against the Government based upon its handling of the criminal case against Epstein. (See In re Jane Doe Litigation, Court File No. 08-80736-Civ-Marra.) There has been no allegation, and certainly no showing, that the civil litigation is a ruse to obtain discovery on behalf of the criminal investigation.</p><p block-type='Text' class='has-continuation'>As some of the plaintiffs have mentioned, one purpose of the NPA was to place the identified victims in the same position where they would have been if Epstein had been convicted after trial of an offense enumerated in 18 U.S.C. § 2255. (See, e.g., Court File No. 08-CV-80119 DE 49-2.) If Epstein had proceeded to trial and been convicted, those victims would have been entitled to restitution and to file suit pursuant to 18 U.S.C. § 2255, and would have been entitled to the same sorts of discovery that they now seek. None of the plaintiffs has contacted the United States about passing on materials gathered through discovery to any criminal investigators or about seeking discovery that would be relevant only to the criminal proceedings, rather than to their individual cases. If Epstein has legitimate concerns that the civil discovery process is being abused in some way, he can ask the Court for a protective order limiting the scope of discovery or its distribution. Furthermore, if at some time in the future, Epstein were the subject of a criminal indictment and he alleged that the evidence to be used against him was gathered improperly, he could file a motion to suppress or to dismiss the indictment in that criminal action. See, e.g., United States, ex. rel. Westrick v. Second Chance, 2007 WL 1020808 \*4 (D.D.C. Mar. 31, 2007) (Defendant in civil False Claims Act suit moved to stay civil action pending criminal</p><p block-type='Text'>investigation where no indictment had been returned. The district court denied the motion, noting that while &quot;allowing civil discovery to proceed may afford the government [who was the real party in interest in the civil case] the opportunity to gain evidence that it may not be entitled to under the more restrictive criminal discovery rules, if and when discovery becomes necessary, protective orders and other remedial measures may be taken.&quot;) (citations omitted).</p><p block-type='Text'>By entering into the NPA, with its explicit discussion of 18 U.S.C. § 2255, Epstein acknowledged that the United States was trying to protect the victims&#x27; rights to restitution and that civil claims would likely follow. Epstein did not bargain for a stay of those proceedings. Instead, both parties received benefits and gave consideration for the bargain that was struck — while Epstein is faced with answering discovery requests that he would not face during criminal proceedings, he also is entitled to the identification of and extensive discovery from the victims, which he would not have received in the criminal case. Based upon a review of the discovery requests he has promulgated thus far, it appears that Epstein is taking full advantage of this benefit and if a criminal case were ever filed, he would, no doubt, seek to use that information in his defense.&#x27;</p><p><sup>&#</sup>x27;With respect to the other &quot;special circumstances&quot; mentioned in Incendy, the government obviously advised Epstein of the potential for criminal charges, and that knowledge led to the negotiation of the NPA. Epstein also has a number of attorneys listed on the Service List for the civil cases and has retained a similarly large number of attorneys to handle the criminal investigation and negotiation of the NPA. Epstein alleges a fear of adverse publicity, but as the plaintiffs have pointed out, during the course of the state and federal criminal investigations, Epstein&#x27;s personal publicist distributed stories to the press impugning the credibility of the victims and other witnesses and averring that the victims&#x27; allegations of abuse were made solely to extract money from the defendant. In the context of some of the civil suits currently pending, Epstein has asked the Court</p><p block-type='Text'>Unlike and Incendy, Epstein also has not been criminally indicted. In some districts, this alone is virtually dispositive. See, e.g., Sterling Nat&#x27;l Bank v. A-1 Hotels Internat&#x27;l, 175 F. Supp. 2d 573, 576-77 (S.D.N.Y. 2001) (&quot;district courts in this Circuit `generally grant the extraordinary remedy of a stay only after the defendant seeking a stay has been indicted.&#x27;&quot; (quoting Citibank, N.A. v. 1993 WL 481335 \*1 (S.D.N.Y. Nov. 18, 1993) (add&#x27;/ citations omitted). As one court explained:</p><p block-type='Text'>the consensus that a party seeking a stay bears a heavier burden when he has not yet been indicted derives logically from the balancing test set out by the courts of appeals that have considered the question. When a defendant has been indicted, his situation is particularly dangerous, and takes a certain priority, for the risk to his liberty, the importance of safeguarding his constitutional rights, and even the strain on his resources and attention that makes defending satellite civil litigation particularly difficult, all weigh in favor of his interest. Moreover, if the potential prejudice to the defendant is particularly high post-indictment, the prejudice to the plaintiff of staying proceedings is somewhat reduced, since the criminal litigation has reached a crisis that will lead to a reasonably speedy resolution. Furthermore, at that stage in the criminal proceeding, the contours of the indictment will provide the Court with a reasonable basis for determining the extent of the threat to the defendant&#x27;s Fifth Amendment rights, and the likely extent and timing of the criminal litigation.</p><p block-type='Text'>Pre-indictment, these factors must be balanced significantly differently. Though many of the same risks to the civil defendant are present, the dangers are at least somewhat more remote, and it is inherently unclear to the Court just how much the unindicted defendant really has to fear. Conversely, the delay imposed on the plaintiff is potentially indefinite. There is no telling how complicated the government&#x27;s investigation may be, whether the allegations of the particular civil plaintiff are merely the tip of an iceberg that will result in a lengthy and open-ended investigation, what priority the government assigns to the investigation, whether it will result in charges that will have to</p><p block-type='Text'>to unseal the victims&#x27; names so that he may make use similar press efforts to impugn their credibility.</p><p block-type='Text'>be litigated, or how time-consuming the resulting criminal case will be. Under these circumstances, the likelihood that a civil party can make the necessary showing to obtain the &quot;extraordinary&quot; remedy of a stay is inevitably much reduced.</p><p block-type='Text'>Sterling Nat&#x27;l Bank, 175 F. Supp. 2d at 577 (internal citations omitted).</p><p block-type='Text'>The First Circuit has noted that the decision whether to grant a stay &quot;is highly nuanced ... [and] involves competing interests. Balancing these interests is a situation-specific task, and an inquiring court must take a careful look at the idiosyncratic circumstances of the case before it.&quot; Microfinancial, supra, 385 F.3d at 78. Epstein&#x27;s case is more idiosyncratic than most.</p><p block-type='Text'>As the Court aptly noted in its Order denying Epstein&#x27;s first motion to stay the civil proceedings, Epstein has not been indicted and there are no criminal proceedings pending against him.&#x27; The resurrection of criminal proceedings against Epstein lies entirely within Epstein&#x27;s own hands, by performing or not performing under the terms of the NPA. This tips the balance of equities even further in favor of the plaintiffs. Epstein makes allegations that the U.S. Attorney&#x27;s Office has unfettered discretion in determining breaches of the NPA, but this is no different than in any contractual setting. If one party believes that there has been a breach, it may seek the remedy set forth in the contract. If the other party believes that</p><p><sup>&#</sup>x27;Epstein points to provisions requiring him to maintain certain evidence &quot;inviolate&quot; as proof that the grand jury investigation is still active. These provisions are meant only to insure that easily destroyed evidence identified through the investigation, such as computer equipment, that is still in Epstein&#x27;s control, will still be available to investigators if Epstein does, in fact, breach the NPA. Epstein is well aware that litigation concerning those matters have been removed from the Court&#x27;s docket, at the insistence of the United States, because it fully halted its investigation in accordance with the terms of the NPA.</p><p block-type='Text'>there has been no breach, it has a remedy at law or equity. In this situation, Epstein would be entitled to seek dismissal of the indictment. See United States v. Beeks, 167 Fed. Appx 777 (1 1 th Cir. 2006); United States v. 138 Fed. Appx. 965 (9th Cir. 2005); United States v. , 393 F.3d 540 (5th Cir. 2004).</p><p block-type='Text'>Epstein argues that because he is seeking a finite period of delay — until the time that he asserts that the NPA &quot;expires&quot; — and that, thereafter, he will promptly provide full and complete responses to all discovery, the harm to the plaintiffs is de minitnis. With all respect, this overlooks a number of obvious issues. First, if a stay is imposed until Epstein&#x27;s proposed &quot;expiration date,&quot; it affords Epstein one of two incentives: (a) to delay any intended breach until a time when he believes that the United States has no remedy and then to breach the agreement with impunity (Le, to use the NPA as a shield and a sword); or (b) to delay the civil litigation as long as possible (until shortly before the &quot;expiration&quot; of the NPA), and then, after criminal charges have been filed, to seek a mandatory stay of the civil cases until the criminal case is resolved. Thus, contrary to the assertions of Epstein, the delay is not limited but, instead, is &quot;potentially indefinite,&quot; as Sterling Bank warns. If the U.S. Attorney&#x27;s Office were to proceed criminally, the litigation would likely be very lengthy, and would result in an even greater delay to the plaintiffs?</p><p><sup>&#</sup>x27;The United States also notes that this finite termination to Epstein&#x27;s exposure to potential criminal consequences is illusory. The NPA addresses only certain victims identified during the course of the government&#x27;s investigation. To the extent that any of the plaintiffs who have already filed suit against Epstein do not fall within that group, the NPA does not address potential charges based upon crimes committed against them. The NPA also does not bind any other state or federal prosecutor from pursuing charges for criminal acts committed within their jurisdiction(s). The federal statute of limitations for offenses against children is ten years or the life of the child,</p><p block-type='Text'>The factors to consider include: &quot;(i) the interests of the civil plaintiff in proceeding expeditiously with the civil litigation, including the avoidance of any prejudice to the plaintiff should a delay transpire; (ii) the hardship to the defendant, including the burden placed upon him should the cases go forward in tandem; (iii) the convenience of both the civil and criminal courts; (iv) the interests of third parties; . (v) the public interest[ .. . (vi) the good faith of the litigants (or the absence of it) and (vii) the status of the cases.&quot; Microfinancial, 385 F.3d at 78 (citations omitted).</p><p block-type='Text'>In considering those factors, the United States respectfully recommends to the Court that all of the factors weigh against a stay. In making its decision, the Court should consider that, unlike all of the cases cited herein, Epstein seeks to stay not one suit involving a single plaintiff, but more than a dozen suits filed by individual plaintiffs. Each of those plaintiffs, in turn, impliedly asserts that she is a &quot;crime victim&quot; with the &quot;right to full and timely restitution&quot; and the &quot;right to proceedings free from unreasonable delay.&quot; 18 U.S.C. § 3771(a)(6) &amp; (7). As noted above, one of the purposes of the NPA was to provide these rights to victims identified in the Government&#x27;s investigation. Thus, this factor weighs more heavily for the plaintiffs than in the average civil dispute as it embodies both the plaintiffs&#x27; and the public&#x27;s interests. The victims who were identified in the government investigation, by and large, were without financial assets and had significant counseling needs that could</p><p>whichever is longer. 18 U.S.C. § 3283. Thus, for Epstein (or any other person accused of sexually abusing children) to &quot;wait out&quot; any chance of criminal liability, the court would have to stay civil litigation until all of the plaintiffs have died.</p><p block-type='Text'>be remedied through obtaining restitution from Epstein. In addition to those needs, they have legitimate concerns about memories fading, witnesses becoming unavailable, and dissipation of Epstein&#x27;s assets while the matter is stayed. On the other hand, while the potential harm to the defendant normally weighs in the defendant&#x27;s favor, in this case, Epstein has significant control over whether the criminal investigation remains in abeyance and whether criminal charges are ever filed.</p><h1>CONCLUSION</h1><p block-type='Text'>In accordance with the Court&#x27;s Order, the United States hereby submits that it is not aware of any &quot;special circumstances&quot; that warrant staying all of the civil cases pending the &quot;expiration&quot; of the NPA.</p><p block-type='Text'>Respectfully submitted,</p><p block-type='Text'>R. ALEXANDER ACOSTA UNITED STATES ATTORNEY</p><p block-type='Text'>By: s/A. o r Villafafia A. VILLAFANA Assistant United States Attorney Florida Bar No. 0018255 500 East Broward Boulevard, 7th Floor Ft. Lauderdale, FL 33394 Telephone: 954-356-7255 Facsimile: 954-356-7230</p><h4>CERTIFICATE OF SERVICE</h4><p block-type='Text'>I HEREBY CERTIFY that on May 28, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. According to the Court&#x27;s website, counsel for all parties are able to receive notice via the CM/ECF system.</p><blockquote><p block-type='Text'>ti a lVILLAFASA Assistant United States Attorney Villqfafia</p></blockquote>
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marker2/court-doe-102-v-epstein/EFTA02738878/EFTA02738878.md

@@ -0,0 +1,267 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+CASE NO.: 08-CV-80119- MARRA
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232- MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 4,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+CASE NO.: 08-CV-80380- MARRA
+
+JANE DOE NO. 5, CASE NO.: 08-CV-80381- MARIZA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994- MARRA/JOHNSON
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 7, CASE NO.: 08-CV-80993- MA RRA/
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+C.M.A., CASE NO.: 08-CV-80811-MARRA/JOHNSON
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08-CV-80893-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. II, CASE NO.: 08-CV-80469-
+
+MA RRAi
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+I
+
+JANE DOE NO. 101, CASE NO.: 09-CV-80591-
+
+MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 102,
+
+Plaintiff,
+
+CASE NO.: 09-CV-80656-
+
+MARRA
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## PLAINTIFFS JANE DOE NO. 101 AND JANE DOE NO. 102's REPLY IN SUPPORT OF MOTION TO PROCEED ANONYMOUSLY AND RESPONSE IN OPPOSITION TO MOTION TO COMPEL AND/OR IDENTIFY JANE DOE NO. 101 AND JANE DOE NO. 102 IN THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY'
+
+Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 (together, "Plaintiffs"), by and through their undersigned attorneys, hereby file their Reply in Support of Motion to Proceed Anonymously and Response in Opposition to Motion to Compel and/or Identify Jane Doe No. 101 and Jane Doe No. 102 in Third-Party Subpoenas for Purposes of Discovery, and, as grounds, state as follows:
+
+1. Exposure of Plaintiffs to the public disclosure of their identity and the resultant shame and humiliation accompanying their sexual exploitation is wholly unnecessary and premature, and may cause further damage. Plaintiffs respectfully assert that this Court should first decide the threshold issues of retroactivity and calculation of damages. Plaintiffs, and all other victims of Defendant who have filed an action against Defendant in federal court, will have to litigate these two following threshold issues being reviewed by the Court in the C.M.A. action against Defendant (Case No. 08-CV-80811-MARRA/ I=.): 1) whether the most recent version of the statute, which provides for a minimum recovery of \$150,000 (instead of the previous minimum of
+
+Plaintiffs respectfully file this Reply in the consolidated action, as the issue at hand pertains to discovery issues.
+
+\$50,000) applies to cases arising from incidents predating the 2006 amendment to the statute; and 2) whether the applicable minimum amount is recoverable per incident and/or per count, or per victim. Defendant has attempted to force settlements on any victims as possible without considering the possibility that the minimum amount recoverable under 18 U.S.C. § 2255 is \$150,000 per count and/or per incident. Much of this Court's caseload will be alleviated once the Court resolves these issues related to the minimum recovery; at that point, many of Defendant's victims will likely agree to settle for the minimum statutory damages to which they are entitled, thus obviating Defendant's specified need to destroy his victims' anonymity and expose them to further harm and humiliation.
+
+2. This Court has discretion to deny Defendant's Motion to Compel and/or Identify Plaintiffs in Third Party Subpoenas for Purposes of Discovery. See Doe v. Stegall, 653 F.2d 180, 184 (5th Cir. Aug. 10, 1981)2 ("Fed.R.Civ.P. 26(c) vests in the trial court discretion over litigants' requests for protection from 'annoyance, embarrassment, oppression, or undue burden or expense' in the discovery process.") (internal quotation omitted). As more fully discussed in Plaintiffs' Response to Defendant's Motion to Stay, which is adopted and incorporated herein, Defendant waived his right to contest liability in actions filed pursuant to 18 U.S.C. § 2255. Thus, third party discovery is relevant only if Plaintiffs seek recovery of damages in excess of the statutory minimum. Additionally, if and when the parties are ready to proceed with discovery from non-party sources, the Court can put numerous measures in place to maximize Plaintiffs' anonymity. At the outset, Defendant can obtain records from
+
+<sup>2</sup> In Bonner v. City of Prichard. 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc). this circuit adopted as binding precedent all decisions of the former Fifth Circuit handed down before October 1, 1981.
+
+various non-party sources through Plaintiffs' counsel, who can demonstrate and certify that they have obtained the very records being sought, or through an independent special who could be given releases by Plaintiffs to obtain such records on behalf of Defendant to eliminate any question of authenticity or completeness. If Defendant nevertheless insists on conducting his own third-party discovery (needlessly increasing the cost of litigating these actions and causing unnecessary delay), subpoenas seeking documents from sources such as health care providers or employers should not disclose the type of action or identify Defendant. Because of the highly-publicized nature of Defendant's crimes as well as his designation as a sexual offender, the mere mention of Defendant's name in any subpoena or deposition notice will automatically expose the subject Plaintiff as one of Defendant's victims and may result in unnecessary public humiliation. Similarly, records custodian depositions do not require the disclosure of the nature of the action and/or the identity of the defendant in the action.3
+
+3. Defendant's only purpose in opposing Plaintiffs' motions is harassment. Defendant's intentions are clear. He seeks to destroy these young women by outing them as being among his many victims, a pattern of behavior consistent with his status as a designated sex offender. Defendant openly admits to his desire to reveal the victims' names in newspapers so that individuals in their community can come forward to assault their credibility and tarnish their reputations (and, as a result, their dignity). See Defendant's Response in Opposition to Motion to Proceed Anonymously (DE# 5) at 16 ("[O]nce the Plaintiff is identified, other individuals come forward in the discovery phase with information which often directly contradicts allegations as to the events and
+
+<sup>3</sup> Depending upon claims of Plaintiffs, certain documents will be relevant. At this point, however, Plaintiffs do not waive their privilege to prevent the release of each of their names under the doctor-patient relationship.
+
+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 acts(s) that would negate or lessen her damages"). Each of Defendant's victims whom undersigned counsel represents continues to experience trauma and humiliation associated with sexual abuse. See Ellen Bass & Laura M, The Courage to Heal: A Guide for Women Survivors of Child Sexual Abuse 3 (4th ed. 2008) ("The long-term effects of child sexual abuse can be so pervasive that it's sometimes hard to pinpoint exactly how the abuse affected you. It can permeate everything: your sense of self, intimate relationships, sexuality, parenting, working, even your sanity.")4 The U.S. Supreme Court in Coker v. Georgia, 433 U.S. 584, 597 (1977), discussed the grave nature of the crimes at issue in the cases against Defendant, stating:
+
+[Rape] is highly reprehensible, both in a moral sense and in its almost total contempt for the personal integrity and autonomy of the female victim ... Short of homicide, it is the "ultimate violation of self."
+
+Defendant committed crimes constituting the "ultimate violation of self" against minors. Because of the disdainful nature of these types of crimes, courts, including the Eleventh Circuit, "have carved out a limited number of exceptions to the general requirement of disclosure, which permit plaintiffs to proceed anonymously." Roe v. Aware Woman Or. for Choice, Inc., 253 F.3d 678, 685 (11th Cir. 2001) (internal citation omitted). "The
+
+<sup>4</sup> Although some Plaintiffs no longer live in the Palm Beach area, this should not undermine Plaintiffs' need for anonymity. As the Court in Doe No. 2 v. Kona), 242 F.R.D. 193, 197 (E.D.N.Y. 2006) (internal citation omitted), points out, "[lit is now possible to 'determine whether a given individual is a party to a lawsuit in federal court anywhere in the country by the simplest of computer searches, to access the docket sheet of any such case electronically, and ... that entire case files will be accessible over the Internet." Given the ease with which the public could access court files in these cases, it is reasonable that Plaintiffs' fears extend beyond ostracism in the Palm Beach community. The Palm Beach Post is available online all over the world. In addition, many of Plaintiffs' family members remain in the Palm Beach area and remain unaware of their daughter/granddaughter/nicce's involvement in Defendant's sordid child sex exploitation enterprise. Furthermore. Plaintiffs are exposed to harassment through social networking sites such as Facebook and MySpacc as well as other forms of online harrassment.
+
+ultimate test for permitting a plaintiff to proceed anonymously is whether the plaintiff has a substantial privacy right which outweighs the customary and constitutionally-embedded presumption of openness in judicial proceedings." Id. (internal quotation and citation omitted).
+
+4. Cases regarding sexual assault are the paradigmatic examples of the type of highly sensitive and personal matter that warrant a grant of anonymity. See Doe No. 2 v. Kolko, 242 F.R.D. 193, 195-98 (E.D.N.Y. 2006) (adult plaintiff, who, many years later, alleged that he was sexually abused by rabbi at private Jewish school when he was a child, was entitled to proceed anonymously because he feared retaliation and ostracism from his community); Doe v. 202 F.R.D. 173, 176 (E.D. Pa. 2001) (sexual assault victim granted use of pseudonym); Doe v. M, 105 F. Supp. 2d 40, 44 (E.D.N.Y. 1999) (victim of assault, molestation, and sexual abuse granted anonymity because victim otherwise psychologically and emotionally unable to proceed with action); Roe v. Borup, 500 F. Supp. 127, 130 (E.D. Wis. 1980) ("It is beyond argument that [a suit involving charges of sexual abuse of a child] is a highly sensitive issue"; thus, plaintiffs were entitled to use fictitious names in prosecuting the suit); see also Doe v. Blue Cross & Blue Shield United of Wis., 112 F.3d 869, 872 (7th Cir. 1997) ("[F]ictitious names are allowed when necessary to protect the privacy of children, rape victims, and other particularly vulnerable parties or witnesses."). The intensely personal nature of sexual exploitation creates an unusual case, and, in such a case, the general policy of full disclosure should give way to a policy of protecting privacy in a very private matter. This protection is especially necessary when the Court is dealing with young women who recently were sexually abused as minors.
+
+5. Defendant is using the threat of publicity to attempt to intimidate victims to cause them not to file suit or to settle their claims for the absolute minimum in order for them to avoid being held up to public ridicule and hostility. His intention to attack the victims is at the heart of the protection afforded by numerous rape shield statutes, of which Defendant and his counsel are surely aware. In 1994, Congress amended the Federal Rules of Evidence to promote the strong social policy of protecting a victim's privacy and encouraging victims of crime to come forward. "The reason for extending Rule 412 to civil cases is equally obvious. The need to protect alleged victims against invasions of privacy, potential embarrassment, and unwarranted sexual stereotyping, and the wish to encourage victims to come forward when they have been sexually molested do not disappear because the context has shifted from a criminal prosecution to a claim for damages or injunctive relief." Fed. R. Evid. 412 advisory committee's note. Rule 412 now provides that, in civil trials in federal court involving alleged sexual misconduct, evidence that the victim engaged in other sexual behavior or evidence offered to prove any alleged victim's sexual predisposition can be admitted only in unusual circumstances, none of which apply to Plaintiffs' cases. Fed. R. Evid. 412 (a), (b). "The rule aims to safeguard the alleged victim against the invasion of privacy, potential embarrassment and sexual stereotyping that is associated with public disclosure of intimate sexual details and the infusion of sexual innuendo into the factfinding process. By affording victims protection in most instances, the rule also encourages victims of sexual misconduct to institute and to participate in legal proceedings against alleged offenders." Fed. R. Evid. 412 advisory committee's note; see also Michigan v. Lucas, 500 U.S. 145, 149-50 (1991) (Rape shield statutes represent the valid legislative determination that victims of rape and
+
+attempted rape "deserve heightened protection against surprise, harassment, and unnecessary invasions of privacy."); United States v. Elbert, 561 F.3d 771, 776-77 (8th Cir. 2009) (evidence that child plaintiffs had previously engaged in prostitution was rightfully excluded in federal sex trafficking suit); Stephens v. M, 13 F.3d 998, 1010 (7th Cir. 1994) (Cummings, C.J., dissenting) ("The Indiana rape shield statute furthers laudable and pragmatic goals. It protects victims from needless exposure of their sexual past conduct; [and] ensures that the focus of rape trials remains the guilt or innocence of the accused rather than the sexual history of the complainant."); United States v. Kasto, 584 F.2d 268, 271-72 n.3 (8th Cir. 1978) ("[U]nchastity of a victim has no relevance whatsoever to [the victim's] credibility as a witness. Such a proposition would 'necessarily imply the absurd (corollary) that the extramarital sexual history of a female witness would be admissible to impeach her credibility in any case in which she testified.") (internal citation omitted). Procedural protections such as the rape shield statutes reduce the embarrassment and anguish of trial, encouraging victims to report sexual offenses and offendors. "Without the protection provided by rape shield statutes, victims may find trial an ordeal not worth enduring." Stephens, 13 F.3d at 1010 (Cummings, C.J., dissenting) (quoting 124 Cong. Rec. HI1944 (1978) (statement of Rep. Elizabeth Holtzman)); see Fed. R. Evid. 412 advisory committee's note ("Too often in this country victims of rape are humiliated and harassed when they report and prosecute the rape. ... [R]ape trials become inquisitions into the victim's morality, not trials of the defendant's innocence or guilt ...."). Indeed, "many [victims] find the trial almost as degrading as the rape itself." Fed. R. Evid. 412 advisory committee's note.
+
+6. In addition, Congress enacted the Child Victims' and Child Witnesses' Rights Act (18 U.S.C. § 3509) in an effort to provide protection for victims who, while minors, were victims of physical abuse, sexual abuse, or sexual exploitation, or who have witnessed a crime committed upon another. One of the primary protections provided by the statute is the restriction on the disclosure of the name of, or other information concerning, the victim. See 18 U.S.C. § 3509(d)(3) (2008). Further, pursuant to 18 U.S.C. § 3509(d)(2), "[a]ll papers to be filed in court that disclose the name of or any other information concerning a child shall be filed under seal without necessity of obtaining a court order."
+
+7. Indeed, numerous states, including Florida and New York, have enacted laws to protect the anonymity of sexual assault victims. See Fla. Stat. §§ 794.024, 794.026 (2008); N.Y. Civ. Rights Law § 50-b (McKinney 2009). In 1994, the Florida Legislature passed The Crime Victims Protection Act. The legislative stated purpose for passage of the Act was "to protect the identity of victims of sexual crimes." Ha. AGO 2003-56, 2003 WL 22971082 (Dec. 15, 2003) ("[T]he Legislature intended to make the identity of a victim of a sexual crime confidential in a court record or proceeding.") Under Florida Section 794.024 of the Florida Statutes, court records that identify the name and/or address of a victim of a sexual crime are presumed to be confidential and exempt from public access. Id. That statute further imposes criminal and civil liability for the disclosure or communication of information identifying the victim of a sexual crime. Ha. AGO 2003-56, 2003 WL 22971082 (citing Fla. Stat. §§ 794.024, 794.026 (2008)). Similarly, upon approving New York's rape shield law, then Governor Mario stated, "[S]exual assault victims have unfortunately had to endure a terrible
+
+invasion of their physical privacy. They have a right to expect that this violation will not be compounded by a further invasion of their privacy." 1991 N.Y. Sess. Laws page nos. 2211-12, quoted in Kolko, 242 F.R.D. at 196 (internal citations omitted).
+
+8. Finally, Defendant should be estopped from outing his victims. Plaintiffs attempted to utilize the process established by the Non-Prosecution Agreement ("NPA") with the reasonable expectation that a specific purpose of the NPA was to allow Defendant's victims to maintain anonymity, only to be subjected to deliberate and unreasonable delays and Defendant's failure to engage in meaningful, good faith settlement discussions. This left Plaintiffs no choice but to file suit. Under these circumstances, Defendant should be estopped from seeking to lift anonymity.
+
+9. Many of Defendant's victims are awaiting this Court's decision regarding whether they will be allowed to proceed anonymously before making the difficult decision as to whether to pursue their claims against Defendant. All of Defendant's victims and any future victims of sexual exploitation must know that they can protect what remains of their personal dignity when appealing to the Federal Courts for justice.
+
+WHEREFORE, Plaintiffs respectfully move this Court to grant Plaintiffs' Motion to Proceed Anonymously and to deny Defendant's Motion to Compel and/or Identify Jane Doe No. 101 and Jane Doe No. 102 in Third-Party Subpoenas for Purposes of Discovery.
+
+Date: May 29, 2009
+
+Respectfully submitted,
+
+PODHURST ORSECK, P.A. Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Bar No. 040856 riosefsberg@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 29th 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 Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Bar No. 040856 rjosefsberg@podhurst.com Katherine W. Ezell Fla. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+**SERVICE LIST**
+
+JANE DOE NO. 2 v. JEFFREY EPSTEIN  
+Case No. 08-CV-80119-MARRA/[REDACTED]  
+United States District Court, Southern District of Florida
+
+Robert Critton, Esq.  
+Michael J. Pike, Esq.  
+Burman, Critton, Luttier & Coleman LLP  
+515 North Flagler Drive, Suite 400  
+West Palm Beach, FL 33401  
+Phone: (561) 842-2820  
+Fax: (561) 515-3148  
+[rcrit@bclclaw.com](mailto:rcrit@bclclaw.com)  
+[mpike@bclclaw.com](mailto:mpike@bclclaw.com)  
+*Counsel for Defendant, Jeffrey Epstein*
+
+Jack Goldberger, Esq.  
+Atterbury, Goldberger & Weiss, P.A.  
+250 Australian Avenue South, Suite 1400  
+West Palm Beach, FL 33401  
+Phone: (561) 659-8300  
+Fax: (561) 835-8691  
+[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net)  
+*Co-Counsel for Defendant, Jeffrey Epstein*
+
+Bruce E. Reinhart, Esq.  
+Bruce E. Reinhart, P.A.  
+250 South Australian Avenue, Suite 1400  
+West Palm Beach, FL 33401  
+Phone: (561) 202-6360  
+Fax: (561) 828-0983  
+[ecf@brucereinhartlaw.com](mailto:ecf@brucereinhartlaw.com)  
+*Counsel for Co-Defendant,* [REDACTED]
+
+Jack Scarola, Esq.  
+Jack P. [REDACTED], 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](mailto:jsx@searcylaw.com)  
+[jph@searcylaw.com](mailto:jph@searcylaw.com)  
+*Counsel for Plaintiff C.M.A.*
+
+Adam Horowitz, Esq. Stuart Mermelstein, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Blvd., Suite 2218 Miami, FL 33160 Phone: (305) 931-2200 Fax: (305) 931-0877 ahorowitz@sexabuseattomey.com smermelstein@sexabuseattoney.com Counsel for Plaintiffs in Related Case Nos. 08-80069, 08-80119,08-80232, 08-80380, 08- 80381, 08-80993, 08-80994
+
+Spencer Todd Kuvin, Esq. Theodore Jon Leopold, Esq. Leopold Kuvin, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Phone: (561) 515-1400 Fax: (561) 515-1401 skuvin@leopoldkuvin.com tleopold@leopoldkuvin.com Counsel for Plaintiff in Related Case No. 08-08804
+
+Richard Willits, Esq. Richard H. Willits, P.A. 2290 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 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/court-doe-102-v-epstein/EFTA02738895/EFTA02738895.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80119- MAR RA/-
+
+/
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232- MARR I
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380- MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 5, CASE NO.: 08-CV-80381- MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 6,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+J
+
+CASE NO.: 08-CV-80994- MARRA/
+
+JANE DOE NO. 7, CASE NO.: 08-CV-80993- MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+J
+
+C.M.A., CASE NO.: 08-CV-80811-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08-CV-80893-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. II, CASE NO.: 08-CV-80469- MARRAI
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 101, CASE NO.: 09-CV-80591- MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 102, CASE NO.: 09-CV-80656- MARRA,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+### PLAINTIFFS JANE DOE NO. 101 AND JANE DOE NO 102's MOTION FOR LEAVE TO FILE UNDER SEAL RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY OR. IN THE ALTERNATIVE. TO UNSEAL THE NONPROSECUTION AGREEMENT
+
+Pursuant to Rule 5.4 of the Local Rules of the United States District Court for the Southern District of Florida, Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 (together, the "Plaintiffs") by and through their undersigned attorneys, hereby file this Motion For Leave to File Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Response in Opposition to Defendant's Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings With Incorporated Memorandum of Law Under Seal, and, as grounds, state as follows:
+
+I. Undersigned counsel seek to file this Response in Opposition to Defendant Jeffrey Epstein's Motion to Stay under seal in order to abide by this Court's August 21, 2008 Order to Compel Production and Protective Order entered in Case No. 08-80736- CIV-MARRa (the "Protective Order"). The Protective Order prohibits Plaintiffs from disclosing the Non-Prosecution Agreement (the "NPA") or its terms to any third party. The sealed document should be maintained under seal for the duration of this Court's August 21.2008 Protective Order.
+
+2. Undersigned counsel recognize that this Court has previously unsealed documents referring to the NPA. We seek to comply with the Protective Order for this new and independent filing in an abundance of caution, until directed otherwise by the Court.
+
+3. If this Court denies Plaintiffs' instant motion, Plaintiffs seek appropriate disclosure of the NPA pursuant to this Court's recent order in Case No. 08-80736-CIV-MARRa (DE #36) denying Plaintiffs Jane Doe No. 1 and Jane Doe No. 2's motion to unseal the NPA. As stated in that Order, the NPA has not been filed with the Court. Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 would then have "a specific tangible need to be relieved of the restrictions" of the Protective Order because consideration of the terms of the NPA is necessary for this Court to resolve Defendant's Motion to Stay.
+
+## WHEREFORE,
+
+I. Plaintiffs respectfully request this Court to enter an Order granting Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 the right to file under seal their Response in Opposition to Defendant's Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings With Incorporated Memorandum of Law.
+
+2. In the alternative, Plaintiffs respectfully request this Court to unseal the Non-Prosecution Agreement in order to allow Plaintiffs to concretely respond to Defendant's Motion to Stay.
+
+3. Finally, Plaintiffs respectfully request this Court to grant such other and further relief to which this Court finds the Plaintiff otherwise entitled.
+
+Date: May 29, 2009
+
+Respectfully submitted,
+
+PODHURST ORSECK, P.A. Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Bar No. 040856 rjosefsberg@podhurst.com Katherine W. Ezell Fla. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+# CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+
+On May 29, 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: May 29, 2009
+
+## CERTIFICATE OF SERVICE
+
+WE HEREBY CERTIFY that, on this 29th 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 Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Bar No. 040856 rjosefsberg@podhurst.com Katherine W. Ezell Fla. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+### SERVICE LIST
+
+JANE DOE NO. 2 v. JEFFREY EPSTEIN Case No. 08-CV-80119-MARRa United States District Court, Southern District of Florida
+
+Robert Critton, Esq. Michael J. Pike, Esq. Burman, Critton, Luttier & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 Phone: (561) 842-2820 Fax: (561) 515-3148 rcrit@bciclaw.com mpike@bciclaw.com Counsel for Defendant, Jeffrey Epstein
+
+Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL, 33401 Phone: (561) 659-8300 Fax: (561) 835-8691 jagesq@bellsouth.net Co-Counsel for Defendant, Jeffrey Epstein
+
+Bruce E. Reinhart, Esq. Bruce E. Reinhart, P.A. 250 South Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 202-6360 Fax: (561) 828-0983 ecf@brucereinhartlaw.com Counsel for Co-Defendant,
+
+Jack Scarola, Esq. Jack P. 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 jph@searcylaw.com Counsel for Plaintiff C.M.A.
+
+Adam Horowitz, Esq. Stuart Mermelstein, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Blvd., Suite 2218 Miami, FL 33160 Phone: (305) 931-2200 Fax: (305) 931-0877 ahorowitz@sexabuseattomey.com smermelstein@sexabuseattomey.com Counsel for Plaintiffs in Related Case Nos. 08-80069, 08-80119,08-80232, 08-80380, 08- 80381, 08-80993, 08-80994
+
+Spencer Todd Kuvin, Esq. Theodore Jon Leopold, Esq. Leopold Kuvin, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Phone: (561) 515-1400 Fax: (561) 515-1401 skuvin@leopoldkuvin.com tleopold@leopoldkuvin.com Counsel for Plaintiff in Related Case No. 08-08804
+
+Richard Willits, Esq. Richard H. Willits, P.A. 2290 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 bedwardserra-law.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/court-doe-102-v-epstein/EFTA02738905/EFTA02738905.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5, CASE NO.: 08-CV-8038I -MARRA/JOHNSON
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRA/M.
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 7, CASE NO.: 08-CV-80993-MARRA,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+C.M.A., CASE NO.: 08-CV-80811-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08-CV-80893-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. II, CASE NO.: 08-CV-80469-MARRA/M.
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARRAM=
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 102, CASE NO.: 09-CV-80656-MARRAi
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+MOTION TO RESCHEDULE HEARING
+
+COMES NOW Robert C. Josefsberg, as co-counsel for Jane Doe 101 and 102, and respectfully requests either a rescheduling of this Court's hearing (just rescheduled for June, 12, 2009) or in the alternative, permission to appear by telephone at said hearing, on the following grounds:
+
+I) On Wednesday, June 10, 2009, undersigned counsel, his wife and two granddaughters will be traveling to Hanover, New Hampshire for counsel's 50th College Reunion, and an opportunity for his two high school granddaughters to visit colleges in the Northeast. Counsel is scheduled to return to South Florida on Tuesday, June 16".
+
+2) Counsel is very appreciative and supportive of the Court's scheduling a hearing on the Defendants' Motion to Stay. That hearing was scheduled ( within the last 3 hours) for Friday, June 12th at 10:00 a.m. , right in the middle of Robert Josefsberg's reunion visit.
+
+3) If Robert Josefsberg cannot attend, Jane Doe 101 and 102 will be well represented by co-counsel who can and will appear in person at said hearing on June 12, 2009. However, Robert Josefsberg is lead counsel and would prefer to be present during said hearing.
+
+4) In the event that this hearing cannot be rescheduled for June 4, 5, 8 or 9th, or June lr , le or 19", Robert Josefsberg requests permission to appear at said June 12th hearing by telephone.
+
+WHEREFORE, Robert Josefsberg requests the relief requested above.
+
+Dated May 29, 2009.
+
+Respectfully submitted,
+
+PODHURST ORSECK, P.A. Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+By: s/ Robert C. Josefsberg Robert C. Josefsberg Fla. Br No. 040856 rjosefsberg@podhurst.com
+
+> Katherine W. Ezell Fla. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Hagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+## 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 Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+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. 2 v. JEFFREY EPSTEIN Case No. 08-CV-80119-MARRa United States District Court, Southern District of Florida
+
+Robert Critton, Esq. Michael J. Pike, Esq. Burman, Critton, Luttier & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 Phone: (561) 842-2820 Fax: (561) 515-3148 rcrit@bcIclaw.com mpike@bciclaw.com Counsel for Defendant, Jeffrey Epstein
+
+Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691 jagesq@bellsouth.net Co-Counsel for Defendant, Jeffrey Epstein
+
+Bruce E. Reinhart, Esq. Bruce E. Reinhart, P.A. 250 South Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 202-6360 Fax: (561) 828-0983 ecf@brucereinhartlaw.com Counsel for Co-Defendant,
+
+Jack Scarola, Esq. Jack P. 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 jph@searcvlaw.com Counsel for Plaintiff C.M.A.
+
+Adam Horowitz, Esq.
+
+Stuart Mermelstein, Esq.
+
+Mermelstein & Horowitz, P.A.
+
+18205 Biscayne Blvd., Suite 2218
+
+Miami, FL 33160
+
+Phone: (305) 931-2200
+
+Fax: (305) 931-0877
+
+ahorowitz@sexabuseattomey.com
+
+smermelstein@sexabuseattornev.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
+
+Jawverwillits@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 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/court-doe-102-v-epstein/EFTA02738914/EFTA02738914.md

@@ -0,0 +1,274 @@
+## -UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232-
+
+NL RI
+
+Plaintiff;
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380-
+
+MARRA
+
+Plaintiff;
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 5, CASE NO.: 08-CV-80381-
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994- MARRiV
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant
+
+JANE DOE NO. 7,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE .N 08-CV-80993- MARRA
+
+C.M.A., CASE NO.: 08-CV-8081I-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08-CV-80893-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. II, CASE NO.: 08-CV-80469-
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 101, CASE NO.: 09-CV-80591- MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 102, CASE NO.: 09-CV-80656- MA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## PLAINTIFFS JANE DOE NO. 101 AND JANE DOE NO. 102's REPLY TO DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NO. 101 AND JANE DOE NO. 102'S MOTION FOR A NO-CON'I'ACT ORDER
+
+Plaintiffs, JANE DOE No. 101 and JANE DOE No. 102 (together, the "Plaintiffs"), by and through undersigned counsel, hereby reply to Defendant Jeffrey Epstein's Response to Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-Contact Order (" Response") as follows:
+
+1. Plaintiffs have not, and will not, engage in any name-calling. For purposes of Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-Contact Order ("Motion"), it does not matter whether "many of the alleged victims .. . were or are admitted prostitutes, dancers at strip clubs .. . or have criminal records or warrants for their arrests . . .," Def.'s Resp. 4, or whether they were living in a monastery or planning on becoming nuns, lawyers, or judges. This matter is quite simple: The allegations are that, when these victims were minors, Defendant sexually exploited, abused, molested, and/or battered them. Regardless of the victims' character or Defendant's character, it is obvious that Defendant, Jeffrey Epstein, a 55-year-old designated sexual offender and convicted felon, should have no contact with his victims.
+
+2. Defendant makes much ado that one victim allegedly telephoned Jack Goldberger's office to complain that Mr. Goldberger was holding up the matter. Del 's Resp. 5. We have no reason to doubt the truth of that statement by defense counsel. Unsurprisingly, a 21-year-old homeless, ill, and desperate victim who had waited for settlement funds for seven weeks regretfully may have called Mr. Goldberger's office; but whether she did so has nothing to do with Plaintiffs' Motion. Likewise, if Defendant attempts to telephone undersigned counsel to complain or have any other contact with undersigned counsel, undersigned counsel will handle the matter as professionally as Jack Goldberger did—by refusing to speak to the opposing party.
+
+3. The troublesome part of Defendant's position is his counsel's statement in the attached correspondence that, pursuant to Rule 4-4.2 of the Rules of Professional Conduct, "parties to a matter may communicate directly with each other . . . ." In this case, Plaintiffs' counsel are concerned that Defendant or his agents may assert that alleged right, and we vehemently disagree that they should have that prerogative in these Plaintiffs' cases. No legal justification exists for Defendant or his agents to have any direct communications with victims whom Defendant, Jeffrey Epstein, sexually exploited, abused, molested, and/or battered.
+
+In his Response, see Def.'s Resp. 4, and in his letter, counsel for Defendant, Jeffrey Epstein, professes that "it is not Mr. Epstein's intention to have any direct contact with [our] clients." This statement poses two significant problems. First, it leaves the door open for Defendant's investigator(s) or other agent(s) to contact the victims. Such contact would not be direct and would not be inconsistent with his professed intention to refrain from direct contact with his victims. See, e.g., v. All State Home Mortgage, Inc, No. 08-3564, 2009 WL 1391527, at \*1 (6th Cir. May 15, 2009) (intimidation of plaintiffs-loan officers with contentious relationship with defendant-mortgage company
+
+through threatening phone calls by defendant's employees considered indirect contact in violation of no-contact order in civil suit claiming violation of Fair Labor Standards Act); Commonwealth v. M, 661 N.E. 2d 666, 666-67 (Mass. App. Ct. 1996) (defendant's anonymous delivery of flowers to victim considered indirect contact in violation of nocontact order). Second, Defendant's counsel does not state that Defendant will not have any contact with his victims. He merely states Defendant's intentions. Unfortunately, the last five months is replete with other incidents in which Defendant, through his counsel, has stated his intentions and thereafter changed his mind. Defendant, Jeffrey Epstein, feels free—and actually is free—to change his mind and his stated intentions. His victims deserve more than that. Because they are traumatized and fearful, they require for their security a firm, unambiguous commitment that Defendant will not directly or indirectly contact either of them; considering the situation, any secure commitment is attainable only via a Court order. Plaintiffs cannot emotionally afford to be in a position in which Defendant can unilaterally change his mind.
+
+4. In the event that Defendant wants to be present at the deposition of a Plaintiff or at a Court hearing where a Plaintiff is to attend, the Court can easily resolve such situations at that time. Meanwhile, the sole purpose of Defendant's refusal to agree to not contact these Plaintiffs is to leave them intimidated and in fear of being in the presence of the man who has sexually exploited, abused, molested, and/or battered them. One would think that, instead, Defendant would have voluntarily agreed with Plaintiffs' prior request to have no contact directly or indirectly, including through his agents, and would want to demonstrate to the Court that he will not contact his victims; his refusal to stay away from them is nothing short of disturbing.
+
+5. Although not requested, if Defendant's counsel seeks some type of reciprocity, Plaintiffs' counsel would agree in writing, and would not oppose a Court order prohibiting Plaintiffs from contacting Defendant, Jeffrey Epstein. It is obvious to undersigned counsel that there should be absolutely no contact between the parties to these lawsuits.
+
+WHEREFORE, Plaintiffs request this Court to enter an Order prohibiting Defendant, Jeffrey Epstein, and/or his agents from directly or indirectly contacting them.
+
+Dated: June 4, 2009.
+
+Respectfully submitted,
+
+PODHURST ORSECK, P.A. Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+By: s/ Robert C. Josefsberg Robert C. Josefsberg Fla. Bar No. 040856 riosefsbera@podhurst.com Katherine W. Ezell Fla. Bar No. 114771 kezell©podhurst.com City National Bank Building 25 W. Flagler Street, Ste. 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+## CERTIFICATE OF SERVICE
+
+WE HEREBY CERTIFY that, on this 4th day of June, 2009, we electronically filed the foregoing document with the Clerk of the Court using CMJECF. 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 ORSECIC, P.A. Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Bar No. 040856 riosefsberrt@oodburst.com Katherine W. Ezell Ha. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Ste. 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+**SERVICE LIST**
+
+JANE DOE NO. 2 v. JEFFREY EPSTEIN  
+Case No. 08-CV-80119-MARRA/ [REDACTED]  
+United States District Court, Southern District of Florida
+
+Robert Critton, Esq.  
+Michael J. Pike, Esq.  
+Burman, Critton, Luttier & Coleman LLP  
+515 North Flagler Drive, Suite 400  
+West Palm Beach, FL 33401  
+Phone: (561) 842-2820  
+Fax: (561) 515-3148  
+[rcrit@bclclaw.com](mailto:rcrit@bclclaw.com)  
+[mpike@bclclaw.com](mailto:mpike@bclclaw.com)  
+*Counsel for Defendant, Jeffrey Epstein*
+
+Jack Goldberger, Esq.  
+Atterbury, Goldberger & Weiss, P.A.  
+250 Australian Avenue South, Suite 1400  
+West Palm Beach, FL 33401  
+Phone: (561) 659-8300  
+Fax: (561) 835-8691  
+[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net)  
+*Co-Counsel for Defendant, Jeffrey Epstein*
+
+Bruce E. Reinhart, Esq.  
+Bruce E. Reinhart, P.A.  
+250 South Australian Avenue, Suite 1400  
+West Palm Beach, FL 33401  
+Phone: (561) 202-6360  
+Fax: (561) 828-0983  
+[ecf@brucereinhartlaw.com](mailto:ecf@brucereinhartlaw.com)  
+*Counsel for Co-Defendant, [REDACTED]*
+
+Jack Scarola, Esq.  
+Jack P. [REDACTED], 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](mailto:jsx@searcylaw.com)  
+[jph@searcylaw.com](mailto:jph@searcylaw.com)  
+*Counsel for Plaintiff C.M.A.*
+
+Adam Horowitz, Esq.  
+Stuart Mermelstein, Esq.  
+Mermelstein & Horowitz, P.A.  
+18205 Biscayne Blvd., Suite 2218  
+Miami, FL 33160  
+Phone: (305) 931-2200  
+Fax: (305) 931-0877  
+[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com)  
+[smermelstein@sexabuseattorney.com](mailto:smermelstein@sexabuseattorney.com)
+
+*Counsel for Plaintiffs in Related Case Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994*
+
+Spencer Todd Kuvin, Esq.  
+Theodore Jon Leopold, Esq.  
+Leopold Kuvin, P.A.  
+2925 PGA Boulevard, Suite 200  
+Palm Beach Gardens, FL 33410  
+Phone: (561) 515-1400  
+Fax: (561) 515-1401  
+[skuvin@leopoldkuvin.com](mailto:skuvin@leopoldkuvin.com)  
+[tleopold@leopoldkuvin.com](mailto:tleopold@leopoldkuvin.com)
+
+*Counsel for Plaintiff in Related Case No. 08-08804*
+
+Richard Willits, Esq.  
+Richard H. Willits, P.A.  
+2290 10<sup>th</sup> Ave North, Suite 404  
+Lake Worth, FL 33461  
+Phone: (561) 582-7600  
+Fax: (561) 588-8819  
+[lawyerwillits@aol.com](mailto:lawyerwillits@aol.com)  
+[reelrhw@hotmail.com](mailto:reelrhw@hotmail.com)
+
+*Counsel for Plaintiff in Related Case No. 08-80811*
+
+Brad [REDACTED], Esq.  
+Law Office of Brad [REDACTED] & Associates, LLC  
+2028 [REDACTED] Street, Suite 202  
+Hollywood, FL 33020  
+Phone: (954) 414-8033  
+Fax: (954) 924-1530  
+[bedwards@rra-law.com](mailto:bedwards@rra-law.com)  
+[be@bradedwardslaw.com](mailto:be@bradedwardslaw.com)
+
+*Counsel for Plaintiff in Related Case No. 08-80893*
+
+Isidro Manuel [REDACTED], Esq.  
+[REDACTED] Elkins & Boehringer
+
+224 Datura Avenue, Suite 900
+
+West Palm Beach, FL 33401
+
+Phone: (561) 832-8033
+
+Fax: (561) 832-7137
+
+isidrogarciaebellsouth.net
+
+Counsel for Plaintiff in Related Case No. 08-80469

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marker2/court-doe-102-v-epstein/EFTA02738925/EFTA02738925.md

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+## The Psychological Trauma Center a division of Preventive Psychiatry Associates Medical Group, Inc.
+
+Medical Director: Gilbert W. Kliman. M. D.
+
+2105 Divisadcro St . San Francisco. CA 94115 Mane (415)292.7119 Fax (4151749-2802 4191r e.cpertchildosvcluarry corn
+
+Forensic Child Psychiatric Evaluations. Life Care Plans R Testimony
+
+## DECLARATION OF (ALBERT KLIMAN, M. D.
+
+June 4, 2009
+
+## RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES IN DOES V JEFFREY EPSTEIN
+
+- 1. I, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California, CA. Physicians License G55912, declare the following under penalty of perjury: 2.1 have been retained by plaintiffs' law firm, Mermelstein & Horowitz, to give expert testimony. If called as a witness, I would testify truthfully and competently concerning my psychiatric findings about each of the plaintiffs' alleged experiences of sexual abuse, and the enduring effects that I find each of the young women have suffered as a direct result of the sexual acts perpetrated by the defendant.
+- 3. 1 have been asked to respond to the Defense motion, which requests that some of the plaintiffs, who are now adults, should be publicly named. It is my opinion that involuntary public disclosure will result in the plaintiffs experiencing revictimization, albeit by a justice system that is designed to protect them. If their identities are released, the victims will be at-risk of having their personal lives scrutinized by friends, extended family, spouses, children, fellow students, employers and fellow employees, the media and general public. This type of exposure humiliates many victims and represents another betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization, shame and retraumatization.
+- 4. Due to traumatization the plaintiffs are arrested in their development, and even those who are now legally adults are arrested in part to adolescent aspects of psychology.
+- 5. The plaintiffs do not hold their heads high with pride for having been sexually controlled by Mr. Epstein. They hold their heads low with shame. The internal life of a typical adolescent, into late adolescence and early adult years in the best of circumstances, usually involves generous proportions of self-consciousness, shame, selfabsorption and self-doubt and self-blame about sexual acts.
+
+6. Clinically harmful levels of shame, self-consciousness, self-doubt and self-blame are even more prominent among victims of molestations than among the general population.
+
+7. Molested teenagers are particularly vulnerable to wrongful manipulations and special clinical harms from the experiences of shame and humiliation. In fact, shame and efforts to cope with it played an underlying role in the harm to each plaintiff. Each was lured into Mr. Epstein's sexual lair with the promise of overcoming bodily and sexual shame by earning money and bettering their lot in life. The defendant capitalized on their sexual naiveté, insecurities and effort to better themselves, and he worked hard to overcome their shame at his enlistment of them in his selfish gratifications.
+
+8. The defendant who wishes to make their identities public is one whom the criminal justice system has already determined is a person who has already committed a crime of child molestation. That surely means he has already exploited and manipulated the girls' state of adolescent sexuality, including their embarrassment, awkwardness and bodily self-consciousness. He perverted their nascent and developing moral structures by posing as a generous, avuncular mentor who could coach them about their bodies, sex and love.
+
+The exploitation of adolescent bodies, sex and love is – from a psychoanalytic point of view – an influence on the developing moral conscience of the children, as well as on their sexual urges. Now the ravaging of their internal and private moral conscience is intended by the perpetrator to be made a public ravaging.
+
+9. Among sexual trauma victims, the insidious and destructive persistence of shame, humiliation and associated self-blame is well-documented (Finkelhor and [REDACTED], 1985). Stigmatization, as experienced by a sexual trauma victim, has especially painful and pathologic consequences. Shame lingers and becomes integrated within the adolescent victim's malleable emerging identity, character structure and self image. Moral clarity is distorted. Perceptions of self-blame and guilt are magnified. The impact of shame lends to cultivating a self image of being "spoiled goods."
+
+10. Stigmatization following sexual trauma results in long-term risks that can negatively shape multiple facets of adult development: sexual, emotional, interpersonal and vocational. Stigmatization, which is generally to be avoided among psychiatric patients, increases risks among those – as in our plaintiffs as a group – who experience clinical depression and self-destructive behaviors: drug use, criminal activity, even prostitution.
+
+Stigmatization following abuse is associated with delinquency due to increased anger and affiliation with deviant peers (Feiring et al., 2007).
+
+11. Shame and guilt are important dimensions of both complex and single event, posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in relation to Mr. Epstein.
+
+12. The DSM-IV-TR recognizes both powerlessness and helplessness as requisite parts of the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder trauma (██████████ Seligman, recent Past President of the American Psychological Association, coined relevant terms of “learned helplessness and “Loss of Personal Locus of Control.” See Seligman, M.P. 1975: Helplessness, Depression, Development and Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal locus of control to a much more experienced, sexually aggressive, powerful and dominant, manipulative perpetrator.
+
+13. Releasing names of the plaintiffs to the public will reenact experiences of powerlessness and helplessness in the face of a boundary violation. Repetition and reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of posttraumatic stress disorder trauma. In effect, release of their identity and public intrusion into their personal life represents a reenactment of the shame of sexual traumatization. Repetition and reenactment are central pathologies that afflict sexual trauma survivors.
+
+14. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial, as a defensive means to manage overwhelming affects associated with the sexual trauma. Each of the plaintiff girls has employed some variation of this defense, both during the massages and then subsequently following disclosure of the abuse. Primitive, maladaptive responses of this nature will become additionally reinforced as a result of public disclosure.
+
+15. Another aspect of the plaintiffs’ experience, which is recognized by DSM-IV-TR, is that the trauma was associated with human design factors (such as cruel intention to do harm, rape, torture). Trauma of this origin has a tendency to produce more “severe or long lasting” posttraumatic stress disorder than natural events (DSM IV TR p. 464). A policy of deliberate revelation of the names of the victims would reinforce the sense of design, pattern and policy of human intentions.
+
+16. Negative expectations about significant activities are noted in DSM-IV-TR, as part of Criterion C. Symptoms of foreshortened future are characteristic of a traumatized individual’s clinical course (C4). They expect revictimization. They expect bad outcomes (C7) in their social, educational, vocational, relational plans. They are hypervigilant (Criterion D4) for further trauma, and this affects lifestyle choices and future planning. Hypervigilance is part of the arousal set of criteria. Public disclosure of the victims’ identity will aggravate existing symptoms of hypervigilance.
+
+17. The DSM-IV-TR diagnostic category of “chronic” is justified for each of the plaintiffs. Scientific literature shows that the prognostic consequences of PTSD and residual effects may last for decades (U.S. Dept. of Health, 2005; *Issues in Child Abuse Prevention Number 9 Autumn 1998*: Long-term Effects of Child Sexual Abuse, Paul E Mullen and Jillian Fleming). The lasting impact upon character, identity and moral development will probably affect long-term influences upon adult development. It is more probable than not that stigmatization associated with public disclosure of the
+
+plaintiffs' identities will intensify the scope, nature and severity of the chronic symptom course.
+
+18. In addition to PTSD, shame and humiliation themselves have also been associated with causing clinical depression. Coexisting PTSD and clinical depression places the plaintiff's at increased risk for re-victimization and high risk sexual behaviors (e.g., sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control, 2002) who are in their control. Studies have also shown that chronic symptoms of PTSD, in association with a single episode of Major Depressive Disorder, can produce lifetime adjustment difficulties, which include suicidality (Oquendo et al, 2005; Dube et al, CDC, 2001; Rohde, J. Am. Acad. Child and Adolescent Psychiatry 2005). The plaintiffs will be additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and humiliation associated with public disclosure of their identities.
+
+19. Alternative hypothesis: I have applied the evidence shown from examination and testing of the plaintiffs and relevant observations and information from other professionals while testing an alternative hypothesis: that no harm would result from public disclosure of the plaintiffs' identities. During the evaluations with the six plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR disorder occurred. I established that there were provable and diagnosable injuries, primarily posttraumatic stress disorder and comorbid depression. Based upon these diagnostic signs, it is more probable than not, that exposing the plaintiff's identity to the public is not a trivial concern or one without substantial clinical repercussions. I believe that most child, adolescent and adult psychiatrists would share the opinion that additional psychiatric injury will result from such exposure.
+
+20. However, consider for the sake of argument, that my diagnostic conclusions are incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of taking a history from multiple sources, videotaping and transcribing my initial interview, and reviewing available medical and legal documents. Even if this was the case, and my diagnostic conclusions were faulty, I believe that multiple experts, even those who may now propose publication of the victims' names, would still come to a conclusion that the plaintiff's suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much clinical evidence and scientific literature showing likelihood of substantial psychiatric harm to these sexually abused plaintiffs.
+
+21. To form these conclusions, I have used my extensive experience in forming these opinions. That experience is both as a treating child psychiatrist and separately as a forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally evaluated hundreds of children and adolescents who have suffered sexual abuse. I have made long term followups of many of the children and have treated many adults who have been molested as adolescents. It is my opinion, with a reasonably high degree of medical certainty that the defense motion to allow public disclosure of the plaintiffs' identities is clinically and ethically a wrongful plan. The act of revealing their identities against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
+
+an aggravation of existing diagnostic concerns. It is more probable than not that releasing personal identities will [REDACTED] an exacerbation and magnification of symptoms lending to increased risk of revictimization and retraumatization.
+
+I declare under penalty of perjury under the laws of the State of California that the foregoing statements are true and correct, and that this declaration was executed at San Francisco, California on June 4, 2009.
+
+Sincerely,
+
+![]()Gilbert Kliman, M.D.
+
+Distinguished Life Fellow, American Psychiatric Association
+
+Senior Fellow, American Academy of Child and Adolescent Psychiatry
+
+[REDACTED] Brockman Award Holder, for Distinguished Lifetime Contributions to
+
+Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and Psychiatry
+
+![](_page_4_Picture_122.jpeg)
+
+State of California, City & County of San Francisco
+
+Subscribed and sworn to (or affirmed) before me on this
+
+24 day of June 2009, by Gilbert Kliman
+
+proved to me on the basis of satisfactory evidence to be the person(s) who appeared before me.
+
+![]()

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+professional publications include books and peer-reviewed medical journal articles on mass disasters, most recently concerning the Attack on America.
+
+He was extensively interviewed in 1997 by CBS Dallas TV regarding psychiatric testimony concerning eleven altar boys, testimony which had resulted in a record-making jury verdict against the Archdiocese of Dallas. In April, 1998, Dr. Kliman was interviewed by Channel Four anchorwoman, Linda concerning his Salvation Army project providing the Cornerstone form of psychoanalytic psychotherapy for homeless preschoolers and toddlers,. The Cornerstone project itself was viewed on the Channel II Five O'Clock News. KGO TV interviewed Dr. Kliman concerning a forensic testimony, with a focus on a Stanford football player who had allegedly become a child molester. During the Lewinsky-Clinton matter, Kliman was interviewed by Channel 12/20 concerning psychoanalytic views of leaders having exceptional sexual access to partners and the risk of a position of power overcoming the judgments of such leaders. During 2001 following the World Trade Building terrorism, Dr. Kliman was interviewed by Channel II News and appeared on five occasions thereafter through 2003 concerning the Afghanistan and Iraq wars. In May 2003, he was discussant with U.N. Secretary General Olaru Otonu, featured on Dhubai Business TV concerning the plight of children in war.
+
+In 2004, together with the International Psychoanalytic Association, Dr. Kliman helped organize, establish and supervise a therapeutic preschool project in Buenos Aires. "Cornerstone Argentina" is now in its second year of treating severely disturbed and impoverished preschoolers, with his continuing collaboration.
+
+Following the hurricane disasters of 2005 he collaborated with Mercy Corps and the Children's Psychological Health Center to produce a mental health resource. The result, "My Katrina and Rita Story", a guided activity resource of families who had to deal with the hurricanes. Mercy Corps is distributing copies to 20,000 families.
+
+In 2005, RE DISTURBED PRESCHOOLERS Dr. Kliman helped organs,. establish and supervise a therapeutic project in Piedmont California, at the nonprofit Ann Center.
+
+In 2007, RE HOMELESS CHILDREN: Dr. Kliman helped establish a Reflective Network Therapy service for homeless preschoolers in S ttle. He provided four days of training in that method for the Family Service Center of MI County (located in Seattle), and created an organizational link between The Family Services Center and The Children's Psychological Health Center, Inc. of San Francisco in order to continue serving homeless children in Seattle.
+
+In 2008, Dr. Kliman activated the Reflective Network Therapy services for preschoolers in Seattle. He supervises there in person and by phone and video.
+
+In 2008, RE DISASTER SERVICES: Following the Sichuan Earthquake Disaster of May 12, 2008, Dr. Kliman established a link between Children's Psychological Health Center, Inc., Mercy Corps, and The China America Psychoanalytic Alliance. He created mental health resources (see Publications) which were licensed for mass distribution in China by Mercy Corps.
+
+In 2008, Dr. Kliman helped found a new non-profit organization called Teach with Africa and is a member of its Board of Directors.
+
+**PROFESSIONAL POSITIONS:**
+
+**Medical Director:** The Children's Psychological Health Center, Inc. (a non-profit agency), San Francisco, 1993- Responsible for standards of research. clinical treatment, clinical supervision, staff training and forensic evaluations - reporting directly to the Board of Directors. **Psychiatric Consultant:** Ann [REDACTED] Center, Piedmont, CA. **Psychiatric Consultant:** [REDACTED] County Family Services, Seattle, WA. **Private Practice: Medical Director**, The Psychological Trauma Center, (a division of Preventive Psychiatry Associates, Medical Group, Inc.), San Francisco, 1989-. **Chief Psychiatric Consultant**, Children's Garden, San Rafael, CA, 1990-1991. (Children's Garden is a residential [REDACTED] care facility, consisting of group care cottages and a school.) **Director**, Preventive Psychiatry Services and Unit for Study of Mass Violence and Genocide, St. Mary's Hospital, San Francisco, CA 1987-1989. Private practice of Psychiatry and Psychoanalysis (Adult, Child, and Adolescent), San Francisco, CA, 1985-. **Director** and **Principal Investigator**, [REDACTED] Care Study Unit, Columbia University, College of Physicians and Surgeons, New York, N.Y., 1984-87. **Associate Clinical Professor**, Columbia University, Department of Child Psychiatry, New York, N.Y., 1985-87. **Founder**, **Editor-in-Chief**, the Journal of Preventive Psychiatry, New York, N.Y., 1980-. **Principal Investigator**, NIMH project ("Preventive Mental Health Services for Children Entering [REDACTED] Care"), The Center for Preventive Psychiatry, [REDACTED] Plains, N.Y., 1979-1985. **Consultant**, Children's Television Workshop, New York 1976. **Assistant Clinical Professor**, Mount Sinai Medical School, Department of Psychiatry, New York, N.Y., 1969-70. **Director**, Preventive Psychiatry Service, Elmhurst General Hospital, Queens, N.Y., 1969-70
+
+**GRANTS AWARDED:**
+
+Grants have been received as Principal Investigator for research and service in preventive psychiatry from: The Aaron Norman Foundation, American Chai Trust, [REDACTED] Barrie Foundation, Bydale Foundation, Cheesborough Pond's Inc., Ciba-Giegy Corporation, Julius H. & Bessie R. Cohn Foundation, David and Ruth Kosh Foundation, James [REDACTED] Foundation, Estate of Florence Mascias, Birny Mason Foundation, The Charles and Emma Goldmann Foundation, The Haas Foundation, The Savin Corporation, The Harris Foundation, The Abelard Foundation, AMF Corporation, CNA Financial Corporation, D. & R. Gottesman Foundation, Stella & Charles Guttman Foundation, Longhill Charities, Virginia & Leonard Marx Foundation, The Klingenstein Foundation, The Lavanburg-Corner House Foundation, Herman Muehlstein Foundation, Nestle Corporation, Louise Ottinger Charitable Trust, Pettus Crowe Foundation, Edward & Ellen Roche Relief Foundation, Samuel Rubin Foundation, Savin Business Machines Corp., S. & H. Scheuer Foundation, [REDACTED] Tannenbaum Foundation.
+
+Grants have been received as Principal Investigator for a project to develop nonmedical training in Early Childhood Psychotherapy from: The Cleveland Foundation, The Van Ameringen Foundation. A grant was received for equipment for preschool therapeutic services, from: The Hecksher Foundation. Grants have been received as Principal Investigator for Research in the Etiology of Early Childhood Psychosis from: The Boehm Foundation. Grants have been received as Principal Investigator for Research in Assessment of Preventive Clinical Interventions with Children Entering [REDACTED] Family Care, from: The National Institute of Mental Health (Grant # RO1 MH 27944), and The Harris Foundation. Grants received as Principal Investigator, The Columbia University [REDACTED] Care Study Unit, for development of preventive interventions with [REDACTED] children, from the following foundations: The Daniel and Florence Guggenheim
+
+Foundation, The Dreyfus Foundation, The Seth Sprague Foundation, The Gralnick Foundation, The Harris Foundation, U.S. Trust, and The Scheuer Family Foundation.
+
+Most recent grants:
+
+1996-2002: Support from The Office of Education, Division of Special Education, San Mateo County, California.
+
+1996 The Windholz Foundation, San Francisco, for video documentation of an experimental project concerning treatment of disturbed and traumatized preschool patients in a public education special education division.
+
+1999 Morris Stulsaft Foundation for video-recording facility to document treatment in The Cornerstone Therapeutic School.
+
+1999-2001 The Cadence Corporation - for early childhood treatment services
+
+2000-2001 The Harris Foundation for Cornerstone Therapeutic School.
+
+2000 Funding and Recognition by the State of California: In 2001, The Department of Education, Division of Special Education, certified the Cornerstone Therapeutic School as a nonpublic special education school, allowing public entities to fund the school by contracts with Unified School Districts.
+
+2001 The San Francisco Day Care Corporation — for Cornerstone Therapeutic School.
+
+2001 The Sophie Murvis Foundation for Training of Teachers and Therapists in the Cornerstone Method.
+
+2002, 2003. The Five Foundation for development of The Cornerstone Therapeutic Preschool 2003.
+
+2005 The Sophie Murvis Foundation grant for Training of Teachers and Therapists in the Cornerstone Method.
+
+2005 Mercy Corps for creation of "My Personal Story about Hurricanes Katrina and Rita"
+
+2008 Mercy Corps for creation of "My Sichuan Earthquake Story"
+
+### JANUSZ KORCZAK INTERNATIONAL LITERARY PRIZE:
+
+First place, International Literary Prize including an award of one thousand dollars, for "World's Best Book Concerning the Well-Being of Children"—Awarded to Gilbert Kliman, M.D. and Albert Rosenfeld, co-authors of Responsible Parenthood published by Holt, Rinehart and Winston, New York, 1980
+
+### PUBLISHED PAPERS AND BOOKS:
+
+1. 01. "Adrenal Medullary Function," in G. [REDACTED] *Yearbook of Endocrinology*, Yearbook Publishers, 1955.
+2. 02. Improved Visual Recognition in Hypnotic Versus Control State," *Archives of General Psychiatry*, Vol. 7:155-162, October 1962.
+3. 03. *Children and the Death of a President*, Editor and Contributor (with Martha Wolfenstein, Ph.D.), Doubleday & Company, New York, 1965.
+4. 04. Oedipal Themes in Children's Reactions to the Assassination of President Kennedy," in Wolfenstein and Kliman, *Children and the Death of a President*, Doubleday, New York, 1965.
+5. 05. "The Role of Stimulus Ambiguity in Hypnotic Recognition," (with Eugene Goldberg, M.D.), *Arch. Gen. Psychiat.* 14: 100, Jan. 1966.
+6. 06. "Sharing Truths for Mental Health," in *Mental Health in Our Daily Life*. Mental Health Association, [REDACTED] Plains, New York, 1966.
+7. 07. "A Psychoanalyst Looks at [REDACTED] Violence as a Factor in Black Violence," The Center for Preventive Psychiatry, 1968.
+8. 08. Teacher Recognition of Psychiatric Needs Among Preschoolers," The Center for Preventive Psychiatry, 1968.
+9. 09. *Psychological Emergencies of Childhood*. Grune and [REDACTED], New York, 1968.
+10. 10. "A Psychiatrist Speaks Out: 3,000 Blighted Children of Westchester," The Center for Preventive Psychiatry, 1969.
+11. 11. "On a Vacuum in Mental Health Practices," The Center for Preventive Psychiatry, 1969.
+12. 12. "Psychological Management of the Dying Child," in W. Kutscher (Ed.) *Death and Bereavement*, Charles C. [REDACTED] Company, Springfield, Ill. 1969.
+13. 13. "The Unique Function of the Teacher in an Experimental Therapeutic Nursery School" (with Doris Ronald), The Center for Preventive Psychiatry, [REDACTED] Plains, New York, 1970.
+14. 14. The Open Family Series (Consultant Editor, with Sarah Bonnett [REDACTED], author). A series of five books entitled *About Dying, Making Babies, That New Baby, A Hospital Story*, and *About Handicaps*, [REDACTED] Publishing Co., New York, 1974.
+15. 15. "Death in the Family—Its Impact on Children," Terry [REDACTED] Klein Memorial Lecture. *Behavioral Sciences Tape Library*, Leonia, New Jersey, 1974.
+16. 16. "Death of a Parent Occurring During a Child's Analysis," in *Trauma: Monograph V of the Monograph Series of the Ernst Kris Study Group*, New York, 1974.
+17. 17. "A Case of a Dying Child," in *Trauma: Monograph V of the Monograph Series of the Ernst Kris Study Group*, New York Psychoanalytic Institute, International Universities Press, New York, 1974.
+18. 18. "Analyst in the Nursery: Application of Child Analytic Techniques in a Therapeutic Nursery," *The Psychoanalytic Study of the Child*, Volume 30, New York Times Publishing Company, 1975.
+19. 19. "A Study of Maternal Depression in the First Two Years of Life: A Possible Contributing Factor in the Etiology of Infantile Psychosis and Neurosis" (with Judyth Katz), The Center for Preventive Psychiatry, [REDACTED] Plains, New York, 1975.
+20. 20. Introduction to *Love and Mankind's Future*, by Alexander Arzoumanian, Persepolis Press, New York, 1976.
+21. 21. "Preventive Measures in Childhood Bereavement," in Linzer, N. *Understanding Bereavement and Grief*, Yeshiva University Press, New York, 1977.
+22. 22. "Childhood Mourning: A Taboo Within a Taboo," in Gerber, I., Wiener, A., Kutscher, A., et al., *Perspectives on Bereavement*, MSS Information Corporation, New York, 1979.
+
+1. 23. "Mourning, Memory, and Reconstruction: The Analysis of a Four-Year-Old Maternally Bereaved Girl at Age Sixteen Months" (With [REDACTED], Ph.D.), in *The Psychoanalytic Study of the Child*, Volume 34, The New York Times Press, New York, 1979.
+2. 24. "Facilitation of Mourning During Childhood," in Gerber, I., Wiener, A., Kutscher, A., et al., *Perspectives on Bereavement*, MSS Information Corporation, New York, 1979.
+3. 25. "The Cornerstone Treatment of a Preschool Boy from an Extremely Impoverished Environment" (with [REDACTED], Ph.D.), *The Psychoanalytic Study of the Child*, Vol. 35, The New York Times Press, New York, 1980.
+4. 26. *Responsible Parenthood: The Child's Psyche Through the Six-Year Pregnancy*, Holt, Rinehart, and Winston, New York, 1980.
+5. 27. "Death: Some Implications in Child Development and Child Analysis," in *Advances in Thanatology*, Vol. 4, No. 2, Arno Press, New York, 1980.
+6. 28. "Children in [REDACTED] Care: A Preventive Service and Research Program for a High Risk Population" (with M. Harris Schaeffer, [REDACTED] J. [REDACTED], and Bernard G. Pasquariella). *The Journal of Preventive Psychiatry*, Volume I: 1, 1981.
+7. 29. Editorial(s). *The Journal of Preventive Psychiatry*. Volume I, 1981-1982, Volume II, 1983-4, Volume III, 1985-7, Volume IV, in press.
+8. 30. *Preventive Mental Health Services for Children Entering [REDACTED] Family Care: An Assessment* (with M. Harris Schaeffer, and M. [REDACTED]). The Center for Preventive Psychiatry, [REDACTED] Plains, New York, 1982.
+9. 31. "Summary of Two Psychoanalytically Based Service and Research Projects: Preventive Treatments for [REDACTED] Children" with M. Harris Schaeffer, Ph.D. *J. of Preventive Psychiatry*, Vol. II, No. 1, 1983.
+10. 32. "Three New Areas in Litigation on behalf of Children," in *Child Psychiatry and the Law*, Diane Schekty, Editor, Volume 2, Bruner/Mazel, New York, 1985.
+11. 33. *Preventive Psychiatry: Early Intervention and Situational Crisis Management*, co-editor, with S.C. Klagsbrun, M.D., E.J. Clark, Ph.D., others. The Charles Press, Philadelphia, 1989.
+12. 34. *My Earthquake Story: A Guided Workbook for Children, Parents and Teachers*, with Harriet Wolfe, M.D. and Edward Oklan, M.D. Psychological Trauma Center Press, Kentfield, CA. October, 1989.
+13. 35. "Facilitation of Mourning During Childhood," chapter in *Preventive Psychiatry: Early Intervention and Situational Crisis Management*. (Eds) S. Klagsbrun, G. Kliman, E. Clark, A. Kutscher, R. DeBellis, C. Lambert. The Charles Press, Philadelphia, 1989.
+14. 36. "Toward Preventive Intervention in Early Childhood Object Loss," chapter in Noshpitz, H. and Coddington, D. (Eds) *Stressors and Clinical Techniques in Child Psychiatry*. Charles [REDACTED], NY, 1990.
+15. 37. "Brief Report: Loss of Parental Services—A Guide to Categorization." *J. Preventive Psychiatry and Allied Disciplines* 4:1, 1990. Human Sciences Press, NYC.
+16. 38. "A Methodologic Breakthrough: The Saga of Delivering Effective Primary Preventive Psychotherapy to Groups of [REDACTED] Children." *J. Preventive Psychiatry and Allied Disciplines* 4:1, 1990. Human Sciences Press, NYC.
+17. 39. "The Rise of Adolf Hitler and Other Genocidal Leaders—Psychoanalytic and Historical Symposium (Summary)," *J. Preventive Psychiatry and Allied Disciplines* 4:1, 1990. Human Sciences Press, NYC.
+
+1. 40. Kliman, G. et al (2007). *"Facilitating Effective Coping in Children Following Disasters: A Psychoanalytic Informed Guided Narrative Intervention."* J. Am Psan. Assoc. In Press
+2. 41. Kliman, G. and M.H. Schaeffer, Ph.D. "A Breakthrough in Prediction and Prevention: Diagnoses as Social Predictors for [REDACTED] Children." *J. Preventive Psychiatry and Allied Disciplines* 4:1, 1990 Human Sciences Press, NYC.
+3. 42. "My Flood Story—a Guided Activity Workbook for Children, Families and Teachers," co-authored with Edward Oklan, M.D., Family Development Press, 1010 Sir Francis Drake Blvd, Kentfield, CA 94960.
+4. 43. "My Earthquake Story, A Guided Activity Workbook for Children, Families and Teachers," co-authored with Harriet Wolfe, M.D., Preventive Psychiatry Associates Medical Group, Inc., 2105 Divisadero Street, San Francisco, CA 94115 and Edward Oklan, M.D., Family Development Press, 1010 Sir Francis Drake Blvd, Kentfield, CA 94960.
+5. 44. "Field Notes: [REDACTED] Care: The Personal Life History Book: A Psychoanalytically Based Intervention for [REDACTED] Children," *Journal for the Psychoanalysis of Culture & Society*, Fall 1996 1:2. 159-162.
+6. 45. Kliman G and Zelman A. (1996). "Use of a Personal Life History Book in the Treatment of [REDACTED] Children--An Attempt to Enhance Stability of [REDACTED] Care Placements." Chapter in Zelman A (ed). *Early Intervention with High-Risk Children: Freeing Prisoners of Circumstance*. Jason Aronson, Northvale, NJ. 105-124.
+7. 46. "Cornerstone Project: Analysis in Special Ed Classes," *The American Psychoanalyst*, 1997. 31:2. 27-28
+8. 47. "My Book about Kosovo - a Guided Activity Workbook for Kosovo Children, Families, and their Teachers." English and Albanian Editions, CPHC, 1999, San Francisco.
+9. 48. "My Book about the Attack on America", A Guided Activity Workbook for Children, Families and Teachers, coauthored with Ed Oklan, M.D. and Ann Oklan, M.D. 2001, CPHC, San Francisco.
+10. 49. "Helping Patients and their Families Cope in a National Disaster", The S.F. Medical Society, January 2002. Reprinted in J. L.A. Medical Society, March 2002.
+11. 50. Discussion of Reactive Attachment Disorder. Developmental Pediatrics. 2003.
+12. 51. "My Personal Story About Hurricanes Katrina and Rita – a guided activity workbook to help coping, learning and Healthy expression." The Children's Psychological Health Center, Sept. 24, 2005 San Francisco. Derivative editions by Mercy Corps, Portland, OR.
+13. 52. "My Personal Story About Tropical Storm Stan" English Ed. Feb. 24, 2006, The Children's Psychological Health Center. *Spanish Translation " Mi Historia De La Tormenta Stan" Feb. 2006*
+14. 53. Israeli Terror Book
+15. 54. "Methods for Maximizing the Good Effects of [REDACTED] Care: Evidence Based Strategies to Prevent Discontinuities of [REDACTED] Care and Raise I.Q." International Journal of Applied Psychoanalytic Studies, April, 2006
+16. 55. "My Personal Story about being Homeless" A Guided Activity Workbook to help Children Cope. The Children's Psychological Health Center Jan 15, 2008
+17. 56. "My Sichuan Earthquake Story – A Guided Activity Workbook to help Children Cope" 85 pages. First English Edition May 22, 2008 available for download online at [www.childrenspsychological.org](http://www.childrenspsychological.org). Mandarin edition by CPHC and China America Analytic Association, in press with Mercy Corps June 2, 2008.
+
+- 57. "My Hurricane Story" A Guided Activity Workbook to help Children Cope. The Children's Psychological Health Center. Sept 21, 2008
+
+---
+
+**WORKS IN PROGRESS:** available in Draft:
+
+IQ Rise among Preschoolers with Pervasive Developmental Disorders.
+
+Child Psychoanalytic Contributions to Civil Justice System, submitted by invitation, to Psychoanalytic Inquiry
+
+Books in Draft:
+
+- 1. Reflective Network Therapy: Early Childhood Psychotherapy in the Classroom
+- 2. A Unifying New Theory of Posttraumatic Stress Disorder
+
+**PRESENTATIONS:**
+
+- 01. "Specific Traumas: Selective Review of Literature," presented at the Ernst Kris Study Group, New York Psychoanalytic Institute, New York, 1965.
+- 02. "Psychoanalysis of a Four-Year-Old in a Preschool Group," presented at the American Psychoanalytic Association, Atlantic City, New Jersey, May, 1966
+- 03. "Covert Suicidal Impulses in Maternally Deprived Children" (with Harriet Lubin, M.S.W.), presented at the American Association of Psychiatric Services for Children, Boston, Massachusetts, November, 1969.
+- 04. Children's Reactions to National Events: The 1968 Federal Elections," presented at the American Orthopsychiatric Association, Washington, D.C., 1969.
+- 05. "Facilitation of Mourning During Childhood," presented at the Chicago Psychoanalytic Institute, May 1973.
+- 06. "Preventive Approaches to Preschool Psychiatric Disorders: Some Assessments," presented at the Academy of Child Psychiatry, Washington, D.C., October, 1973.
+- 07. "Biological Drive Derivative Cycles in Preschool Patients," presented at the New York Psychoanalytic Institute Research Seminar, 1974.
+- 08. "Children in National Disasters," presented at the International Association for Child Psychiatry, Philadelphia, Pennsylvania, 1974.
+- 09. "Childhood Mourning: Some Social Aspects," presented at Yeshiva University, New York, October, 1974.
+- 10. "The Center for Preventive Psychiatry's Interventions with Bereaved Children," presented at the second annual conference on "The Impact of Bereavement and Grief on the Family," Yeshiva University, October 15, 1975.
+- 11. "Death: Implication for Psychoanalytic Theory and Practice," presented at The Association for Psychoanalytic Medicine, New York, 1977.
+- 12. "A Psychoanalytic View of an Ancient Mass Disaster: The Mayan Exodus," The Center for Preventive Psychiatry, 1977.
+
+1. 13. "A Psychoanalytic View of Preventive Psychiatry," presented at Stockbridge, Mass., December, 1977.
+2. 14. "The Self-Concept and Healthy Narcissism: Relevance to Preventive Psychiatry," presented at the Westchester Psychoanalytic Society, [REDACTED] Plains, New York, 1978.
+3. 15. "Special Problems of the Single Parent Child," presented at Department of Child Psychiatry, Rutgers Medical School and published by Jason Aronson Psychotherapy Tape Library, New York, 1978.
+4. 16. "The Self-Concept: Its Significance in Prevention of Mental Illness," presented at The Alumni Association of the Chicago Psychoanalytic Institute, Child Psychotherapy Program, Chicago, 1978.
+5. 17. "Treatment of an Impoverished Intellectually Retarded Ghetto Child by the Cornerstone Method" (with [REDACTED] Ph.D.), presented at the American Psychoanalytic Association, New York, 1979.
+6. 18. "Preventive Approaches Among [REDACTED] Children Using Modern Theory of Narcissism," presented at The Department of Psychiatry, Mountainside Hospital, Symposium on Primary Prevention of the Mental and Behavioral Disorders, Mountainside, NJ, 1979.
+7. 19. "The Center for Preventive Psychiatry: Its Relationship to Infant Psychiatry," at the Symposium on Infant Psychiatry, The Center for Preventive Psychiatry, [REDACTED] Plains, New York, 1979.
+8. 20. "Mourning, Memory and Reconstruction," presented at The Westchester Psychoanalytic Association, [REDACTED] Plains, New York, 1980.
+9. 21. "Preliminary Report on Preventive Psychiatric Services for [REDACTED] Children," presented at American Association of Psychiatric Services for Children, 1980.
+10. 22. "Assessment of Primary Preventive Services: Children Entering [REDACTED] Family Care," presented at American Orthopsychiatric Association, May, 1981.
+11. 23. "Psychoanalytically-Based Approaches to the Problems of [REDACTED] Care: A Pilot Project," presented at the American Psychoanalytic Association Interdisciplinary Seminar on Psychoanalytic Observations of [REDACTED] Care, New York, December, 1978. See also report of this Seminar by [REDACTED], T.: "Psychoanalytic Observations of [REDACTED] Care (An Interdisciplinary Seminar of the American Psychoanalytic Association)." *The Journal of Preventive Psychiatry*, Volume I:1, 1981.
+12. 24. "A Project to Deliver and Evaluate Preventive Psychiatric Services," Columbia College of Physicians & Surgeons, Division of Child Psychiatry Grand Rounds, May, 1982.
+13. 25. "New Concepts in Litigation on Behalf of Children," presented at New York Medical College, October, 1982.
+14. 26. "Cruel Experiments of Nature: General Remarks on Childhood Bereavement and Developmental Pathology." Vulnerable Child Workshop, American Psychoanalytic Association, April, 1983.
+15. 27. Facilitation of Mourning During Childhood: Role of The Clinician," presented at New York Hospital, Westchester Division, October, 1983.
+16. 28. "A Questionnaire for Surveying the Practice of Preventive Psychiatry," presented at the American Academy of Child Psychiatry, Prevention Committee, October, 1983.
+17. 29. "Experiences and Problems in Research Concerning Childhood Bereavement," presented at Department of Psychiatry, University of Ottawa, November, 1983.
+18. 30. "Prediction and Prevention with [REDACTED] Children" (co-authored with M. Harris Schaeffer, Ph.D.), presented at American Psychiatric Association, May, 1984.
+19. 31. "Preventive Psychiatry as Applied to [REDACTED] Children," Grand Rounds, [REDACTED] Porter Psychiatric Institute, 1985.
+20. 32. "The Childhood of Adolf Hitler," with Robert Pois, Ph.D., The American Psychoanalytic Association, Denver, May 1985.
+
+1. 33. Seminar on "New Areas in Forensic Psychiatry," at the Robert [REDACTED] law firm, San Francisco, 1986. VIDEOTAPE AVAILABLE
+2. 34. "Children's Reactions to the Challenger Shuttle Disaster," on 20/20 (Television Broadcast), 1986. VIDEOTAPE AVAILABLE
+3. 35. The Fathering of Adolf Hitler," Grand Rounds, McAuley Neuropsychiatric Institute, St. Mary's Hospital, San Francisco, 1986.
+4. 36. "Child Sexual Abuse: Psychoanalytic and Forensic Approaches," Children's Hospital, San Francisco, 1986. VIDEOTAPE AVAILABLE
+5. 37. "Preventive Psychiatry for Children," Training Seminar at McAuley Neuropsychiatric Institute, St. Mary's Hospital, San Francisco, 1987. VIDEOTAPE AVAILABLE
+6. 38. "Multi-Victim Child Sexual Abuse," San Francisco Psychoanalytic Institute Extension Division, October 1987. VIDEOTAPE AVAILABLE
+7. 39. "Children in [REDACTED] Families: Advances in Preventive Psychiatry," Continuing Education Program for Psychiatrists, U.C. [REDACTED], 1988.
+8. 40. "The Mothering of Adolf Hitler," Grand Rounds. McAuley Neuropsychiatric Institute, St. Mary's Hospital, San Francisco, Dec. 1988.
+9. 41. "Adolf Hitler's Mothering: A Child Psychoanalytic View," Westchester Psychoanalytic Society, New York Hospital, January, 1989.
+10. 42. "The Personal Life History Book: Preventive Psychotherapy for Children in Chaos." Department of Child Psychiatry, Harlem Hospital, New York, NY, January, 1989.
+11. 43. Chairman: Symposium April 20-21, 1989. The Rise of Adolf Hitler and Other Genocidal Leaders. Interdisciplinary Unit for Study of Mass Violence and Genocide. St. Mary's Hospital Department of Psychiatry, San Francisco.
+12. 44. "The Mothering of Adolf Hitler," Symposium above. VIDEOTAPE AVAILABLE
+13. 45. "The Fathering of Adolf Hitler," Symposium above. VIDEOTAPE AVAILABLE
+14. 46. Public Media: Following the October 17th earthquake, Dr. Kliman and his Psychological Trauma Center associates appeared on KRON-TV, KFAS, KQED and public service radio network to offer advice and respond to call-in questions regarding earthquake stress and trauma. His *Earthquake Story* guided workbook (see above) was distributed as a public service by San Francisco Community Mental Health Services and the Oakland Bureau of Education to 11,000 teachers in Oakland and San Francisco.
+15. 47. [REDACTED] Psychoanalytic Society: (April 1990) "Simultaneous child and couple therapy: emergence and interpretation of congruent unconscious themes."
+16. 48. University of California College of Medicine, Department of Psychiatry, Irvine. (June 1990) "Prevention of Psychopathology among Children: Systematic Projects with [REDACTED] Children."
+17. 49. Preventive Interventions with Traumatized Children," Grand Rounds California Pacific Hospital Department of Psychiatry, October 20, 1992. VIDEOTAPE AVAILABLE.
+18. 50. Altered Interpersonal Schemas After Life Threatening Childhood Trauma," Center for Study of Consciousness, UCSF, October 1992.
+19. 51. Alterations of Pre-Traumatic Memory and Post Traumatic Schemas," Child Analysis Colloquium, San Francisco Psychoanalytic Institute, November 1992.
+20. 52. Toward A New Theory of Post Traumatic Stress Disorder," Control Mastery Group, San Francisco Psychoanalytic Institute, December 1992.
+21. 53. Severe Psychological Trauma in Very Young Children," Grand Rounds at the Menninger-San Mateo County Hospital Psychiatric Residency Program, March 23, 1993.
+22. 54. Psychological Crises Among Preschoolers," Department of Health, City of San Francisco, April 1993.
+23. 55. Child Analysis Colloquium," San Francisco Psychoanalytic Institute, May 1993.
+
+1. 56. "Loss of Parental Services—a Guide for Clinicians and Attorneys," Children's Psychological Trauma Center, September 16, 1993. (120 min. VIDEOTAPE AVAILABLE.)
+2. 57. Catastrophic Levels of Psychological Trauma—a Guide for Clinicians and Attorneys," Children's Psychological Trauma Center, September 27, 1993 (120 min. VIDEOTAPE AVAILABLE.)
+3. 58. Systematic Preventive Interventions with ██████████ Children," Keynote Address, Western Pennsylvania Psychiatric Institute Conference on Adoption and ██████████ Care, Sept. 22, 1993.
+4. 59. Cost Benefits of Preventive Interventions with ██████████ Children," American Behavioral Health Institute, San Francisco, Sept. 28, 1993. (60 min. VIDEOTAPE AVAILABLE.)
+5. 60. True and False Allegations of Child Molestation," Children's Psychological Trauma Center, October 1, 1993. (120 min. VIDEOTAPE AVAILABLE).
+6. 61. Severe Psychological Trauma in Childhood—Some New Observations," Grand Rounds, Dept. of Child Psychiatry, Oakland Children's Hospital, Oct. 7, 1993. (60 min. VIDEOTAPE AVAILABLE.)
+7. 62. Preventive Approaches in Severe Psychological Trauma," Bar Association of San Francisco, October 28, 1993. (90 min. VIDEOTAPE AVAILABLE.)
+8. 63. New Theory of Post Traumatic Stress Disorder," Pediatric Grand Rounds California Pacific Hospital, Nov. 5, 1993.
+9. 64. Preventing Depression in Yourself, Your Clients and Your Co-Workers," San Francisco Bar Association, San Francisco, CA, December 2, 1993.
+10. 65. A New Theory of Post Traumatic Disorders," Center for Preventive Psychiatry, ██████████ Plains, NY, January 11, 1994.
+11. 66. KRON-TV, "Helping Children Deal with Earthquake Stress," San Francisco, CA, January 20, 1994.
+12. 67. Samuel Kahn Memorial Lecture, The Center for Preventive Psychiatry, ██████████ Plains, N.Y. Topic, "Catastrophic Traumas of Childhood—New Findings, New Theory, New Therapeutic Tasks," February 28, 1994.
+13. 68. "Preventing Job Stress: The Disease of the 20th Century," San Francisco Bar Association, San Francisco, CA, March 25, 1994.
+14. 69. "Controlled Assessment of Psychoanalytically Derived Psychotherapy with ██████████ Children," American Psychoanalytic Association, Philadelphia, PA, May 1994.
+15. 70. "A senior researcher's subjective experience of a new hypothesis," California School of Professional Social Work Studies. Commencement Address, May 1994.
+16. 71. "Oppositionalism Among Traumatized Children," International Association Child and Adolescent Psychiatry, San Francisco, CA, July 23, 1994.
+17. 72. "New Theory of Posttraumatic Stress Disorder," International Association Child and Adolescent Psychiatry, San Francisco, CA, July 25, 1994.
+18. 73. "Violence Against Young Children—Children in War," Co-sponsored by San Francisco Psychoanalytic Institute, San Francisco, CA, July 26, 1994.
+19. 74. "Method for Treatment of Preschool Psychiatric Patients in Groups," American Psychoanalytic Association, Philadelphia, PA, December 15, 1994.
+20. 75. "A New Theory of Posttraumatic Stress Disorder," Control-Mastery Research Group, San Francisco Psychoanalytic Institute, March 31, 1995.
+21. 76. "New Theory of Child Abuse Effects," T.A.S.K., Monterey, CA, April 1, 1995.
+22. 77. "Psychological Trauma, Day Care and Mental Health," San Francisco Psychoanalytic Institute Extension Division. April 26, 1995.
+23. 78. "Special Problems of Medical Ethics in Psychiatric Treatment: Child Abuse Concerns," San Francisco Psychoanalytic Institute Research Group, June 30, 1995.
+
+- 79. "Operational Confirmation of aPsychoanalytic Hypothesis: Detecting and Interfering with The Repetition Compulsion," Cleveland Psychoanalytic Institute and Anni Katan Center for Child Development, October 28, 1995.
+- 80. The Personal Life History Book Method: Reducing Transfers Among MI Family Homes," The Center for Preventive Psychiatry, =Plains, NY, October 30, 1995.
+- 81. "A New Theory of Posttraumatic Stress Disorder," Grand Rounds, Baylor University School of Medicine, Houston, November 8, 1995.
+- 82. "Raising IQ's in aTherapeutic Nursery: The Cornerstone Method. How it works as illustrated by video clips of the therapist and patients in the classroom," The Houston Psychoanalytic Institute and Stedman West Child Development Center, Houston, TX, November 8, 1995.
+- 83. "The Difficult Client: Accredited Continuing Legal Education seminar for California Attorneys." The Psychological Trauma Center, The Psychological Trauma Center, 1996.
+- 84. "Catastrophic injuries and psychological trauma: Accredited Continuing Legal Education seminar for California Attorneys." The Psychological Trauma Center, 1996.
+- 85. "Why Small Clients Get Large Awards: Proving and Disproving Psychological Injuries in Childhood. Accredited Continuing Legal Education seminar for California Attorneys." 1996
+- 86. "A New Public Health Approach in Public Special Education: Presentation to The San Mateo Board of Education," San Mateo, CA. April 17, 1996.
+- 87. A new model for special education of preschoolers: The Cornerstone Method -- for synergy between early childhood education and psychotherapy. California State Dept. Education, Division of Special Education September 1996, Red Lion Hotel, Orange County Airport, CA.
+- 88. "Synergy Between Special Education and Psychotherapy in the Classroom: Special Education Learning Program Administrators," San Mateo, CA. October 10, 1996.
+- 89. "The Role of Psychoanalyst as Forensic Expert in Catastrophic Psychological Trauma Cases." American Psychoanalytic Association, Winter Meeting, Waldorf Astoria, NY. December 1996
+- 90. "Controlled Assessment of aPsychoanalytically Derived Psychotherapy." American Psychoanalytic Association, Winter Meeting, Waldorf Astoria, NY December 1996.
+- 91. "Child Psychotherapy Course: Several preschool patients with different diagnosis, treated in <sup>a</sup>preschool therapeutic nursery, showing response to interpretations, with discussions of the role of teacher, parents and medications." San Francisco Psychoanalytic Institute, March 4, 11, 18, 1997
+- 92. "Synergy between Psychotherapy and early childhood special education" SELPA Administrators, April 17, 1997
+- 93. "Analyst in the Nursery: The Cornerstone Method," San Francisco Psychoanalytic Institute, May 21, 1997
+- 94. "Psychological Trauma Among Preschoolers," San Francisco Psychoanalytic Institute, May 15, 1997
+- 95. ACT for Mental Health, April 17, <sup>1997</sup>
+- 96. "New Theory of Posttraumatic Stress Disorder," Fifth European Conference on Traumatic Stress, European Society for Traumatic Stress Studies, July 1, 1997.
+- 97. The Cornerstone Method: Intensive Preschool Psychotherapy in Public School Special Education Classes. California State Federation/Council for Exceptional Children 48th Annual Conference & Special Education Fall Conference, San Francisco, CA, October 21- 24, 1998.
+- 98. Research and treatment with highly traumatized preschoolers. Institute, Berkeley, Feb. 4, 2002.
+
+1. 99. Five year and thirty-three year follow ups of early childhood psychotherapy: Some startling findings among children treated by The Cornerstone Method. Grand Rounds, Dept. of Psychiatry, California Pacific Medical Center, San Francisco, February 1, 2000. (VIDEOTAPE AVAILABLE).
+2. 100. Post-Traumatic Stress Disorder and new methods of treatment. Department of Mental Health, State of Oklahoma, and Dept. of Psychiatry, Oklahoma State College of Medicine. Two Days of Workshops and Seminars to fellows, residents in psychiatry and child psychiatry, medical students, and mental health clinicians. October 22, 23 2000.
+3. 101. A Psychoanalytic Treatment of Young Children: Surprisingly Measurable Positive Outcomes”, San Francisco Psychoanalytic Institute - Extension Division Discussion for Clinicians, 03.05.2001
+4. 102. Regarding the 9/11/2002 Attack on America.
+
+2001-2002 Attack on America Events: 2001-2002 Public Health/ Public Education Activities:
+
+Seminar for Parents on Crisis Management following 9/11: Convent of Sacred Heart Elementary School Seminar for Teachers on Crisis Management following 9/11: Stuart █ and Convent of Sacred Heart Elementary Schools Federal Emergency Management Agency: Web-Site Linkage for CPHC's advice to parents and teachers American Academy of Child and Adolescent Psychiatry: Web-Site Linkage for free copies of guided activity workbook for children, parents and teachers.
+
+American Psychoanalytic Association: Web-site linkage for free copies of guided activity workbook for children, parents and teachers.
+
+Channel II: Three interviews on primary prevention of the effects of psychological trauma and terror
+
+Channel II: Three interviews on secondary prevention via early life psychiatric treatment of children
+
+1. 103. Day Long Workshop on The Cornerstone Method. The Children's Psychological Health Center, Feb. 4, 2001, San Francisco.
+2. 104. Child psychoanalysis. San Francisco Psychoanalytic Institute. Six seminars to child analysts and advanced students, using illustrations from parent-permitted videos of the author's recent treatment work with young children.
+3. 105. Theory and Intervention regarding Early Childhood Trauma: Extension Division, San Francisco Psychoanalytic Institute.
+4. 106. Educating and treating disturbed young children: Office of Education, County of San Mateo, ten conferences a year. (1995- 2002)
+5. 107. The Cornerstone Method of educating and treating disturbed young children: 45 conferences a year, Children's Psychological Health Center, San Francisco. (1999- continuing)
+6. 108. New methods for treatment of traumatized and/or developmentally disordered young children. Northern California Mental Health Association, February 9, 2002. A day long workshop. Eureka, Ca.
+7. 109. Research and treatment with disturbed and traumatized young children. █ Institute, Berkeley, Feb 4, 2002.
+
+- 110. Presentations of video-taped child treatment sessions: The Child Analysis Study Group of the San Francisco Psychoanalytic Institute, six occasions 2001-2002.
+- 111. New Theory and New Treatments of Children. Northern California Society of Mental Health Professionals. Feb 8, 2002.
+- 112. Treatment of Children in their Real Life Spaces. Ann Center, Berkeley, CA February 2, 2002.
+- 113. Treatment of children in community school settings. Workshop on Community Child Psychiatry. American Academy of Child and Adolescent Psychiatry. October 2002.
+- 114. Treatment of preschoolers in real life space The Cornerstone Method. A two day training workshop for the L.A. County Dept. of Mental Health. October 2002.
+- 115. The Cornerstone Method. The American Psychoanalytic Association, Workshop on Early Childhood. January 2003, New York.
+- 116. Treatment of Three Autistic Preschoolers: The American Psychoanalytic Association. June, 2003. Boston.
+- 117. The Personal Life History Book: A Preventive Therapy for Children. A day-long workshop at Counseling4Kids, Los Angeles, September 2003.
+- 118. A new method of treatment of autistic preschoolers. The Chinatown Child Development Center, San Francisco, December 4, 2003.
+- 119. Results of the Cornerstone Method: Pervasive Developmental Disorder with eight month to <sup>37</sup>year followup. The M.I.N.D. Institute, U.C. MIE, December 19, 2003.
+- 120. Procedures for preventing and reducing psychopathology among children. Joint Committee of AACAP and Child Welfare League, November 2003, with Marilyn Benoit, M.D.
+- 121. The Role of Child Psychiatrists in Prevention of Child Abuse: Forensic Child Psychiatry as <sup>a</sup>Societal Influence. Mensa Society, January 2004.
+- 122. Psychoanalysis Confronts Autism. The L.A. and SoCal Psychoanalytic Institutes, February 22, 2004.
+- 123. Child Psychiatric Testimony and the Leading Edge of Social Change. American College of Forensic Psychiatry, March 28, 2004
+- 124. The Cornerstone Method of Treating Autism. American Psychoanalytic Association, Boston, Mass., January 2005.
+- 125. An evidence based method for in-classroom treatment of disturbed preschoolers. Child Welfare League of America. New Orleans, MS005.
+- 126. Two evidence-based methods for treating children. International Psychoanalytic Association, Rio de Janeiro, Brazil, July 2005.
+- 127. A novel evidence-based method for treatment of Asperger's Disorder. Lorman Educational Seminars, Redding, CA. November 18, 2005
+- 128. "Applications of The Cornerstone Method to Children with Autism Spectrum Disorders" American Psychoanalytic Association, New York, New York. January 18, <sup>2006</sup>
+- 129. "Applying The Cornerstone Method in Public Schools" Philadelphia Board of Education April 28,06 DVD FORMAT AVAILABLE
+- 130. "Crises Intervention Techniques Within Schools: What you Need to Know When Large or Small Scale Disasters Strike" Lorman Educational Seminar, Sacramento, CA Oct. 6, <sup>2006</sup>
+- 131. "Saying Goodbye: Termination in Psychotherapy" 53"<sup>I</sup> Annual Meeting of The American <sup>c</sup>Aca <sup>i</sup>Ain of Child and Adolescent Pi/linty, San Diego, Ca October 28, <sup>2006</sup>
+- 132. LE, Viron M, JE, A, Samples G, Klitnan G: A school-based mental health recovery effort. Poster session presentation at the 58th Institute on Psychiatric Services Annual Meeting, New York, NY, October 5-8, 2006.
+
+- 133. Viron M, JE,M A, Samples G, Klima G, O'Neill P. A School-based Mental Health Recovery Effort. Poster session presentation at ADMSEP Annual meeting. Park City, Utah, June, 2007.
+- 134. Mishkin, AD, Viron M, LE, Mt JE, Samples G, Kliman G. Reducing Post-Traumatic Stress after Hurricane Katrina: A School-Based Intervention. Poster presented at the 59th Institute on Psychiatric Services Annual Meeting, New Orleans, LA, October 11-14, 2007.
+- 135. Videotape evidence for a new theory of PTSD etiology and treatment. Combined meeting of American Academy of Psychoanalysts with Academy of Psychoanalysis and Psychodynamic Psychiatry, The Marriot, Washington, D.C. May 3, 2008
+
+#### CURRENT TEACHING:
+
+Faculty Member: S.F. Psychoanalytic Institute. Eight 90 minute seminars on Pathogenesis in Early Childhood, with Focus on Psychological Trauma (a course for Candidates in the Child Analysis Program). See also Grand Rounds presentations below.
+
+### THESIS CHAIR ACTIVITIES:
+
+Chairperson, Thesis Committee, California School of Professional Psychology, for Thesis of E. Wayrynen, M.A. concerning "Oppositional Behavior Following Childhood Sexual Abuse." 1998
+
+Chairperson, Thesis Committee, Institute, for Thesis of Miquelon Hope, Ph.D. on IQ and CGAS changes following in-classroom psychotherapy and control group. 1999.
+
+Chairperson, Thesis Committee, Pacific Graduate School of Psychology, for Tina Scovis-Weston, Ph.D., on Early Memory Changes among Twelve Boys Raped by Men. 2001.
+
+#### RECENT AND CURRENT PROFESSIONAL ASSOCIATION COMMITTEE WORK:
+
+Chairperson, Forensic Subconunittee of S.F. Psychoanalytic Institute, 1993-1996. Established liaison with San Francisco Bar Association for a series of Continuing Legal Education Credit seminars presented by a panel of psychoanalysts. Topics presented by G. Kliman, 1993-1994: "Post Traumatic Stress Disorder," "Prevention of Stress in the Workplace," and "Prevention of Depressive Reactions during Legal Practice." Place: S.F. Bar Association.
+
+### CURRENT:
+
+Member, Child Development Program Committee, San Francisco Psychoanalytic Institute.
+
+Member, Child Analysis Study Group, San Francisco Psychoanalytic Institute.
+
+Member, Committee on Psychoanalysis and the Community, American Psychoanalytic Institute.
+
+Member, Joint Committee on Care: Academy of Child and Adolescent Psychiatry and the Child Welfare Association.
+
+#### PROFESSIONAL COMMENDATIONS:
+
+<sup>A</sup>letter of commendation regarding clinical work in the classroom within apublic school system:
+
+December 3, 2001
+
+To Whom It May Concern:
+
+This is to report that the San Mateo County Office of Education, Special Education programs, has benefited from the services of The Children's Psychological Health Center, specifically its Cornerstone Therapeutic School Project.
+
+We have worked together for the past six years. Under the leadership of Gilbert Kliman, M.D., the Center has trained members of our teaching and school psychology staff to carry out <sup>a</sup> mental health service on our premises. We now have acollaborative project in its sixth year for our special education preschool children with Pervasive Developmental Disorders (PDD) and for those with Serious Emotional Disorders (SED) which interfere with their education. As an alternative to sending children to <sup>a</sup>private nonpublic special education school for extremely intensive mental health services at significant cost, this project has created and provides just such intensive service within apublic preschool special class program at 65 Tower Road, San Mateo.
+
+To my knowledge, among the 30 children served so far under the collaborative project, we are seeing cognitive, social and human gains which have decreased the gap between these children and their typically developing peers. Several families and children are thriving with less intensive special education service or returned to regular education class. Not only has the family and child suffering been reduced, the burden to taxpayers is also reduced. The children have been able to remain in the community, and some who were functioning as severely autistic and retarded now appear to be developing within asomewhat normal range. We are pleased with the quality of special education services our County provides for preschoolers with PDD or SED. We are also gratified with the research results provided by The Children's Psychological Health Center.
+
+We recommend the Cornerstone project to other school systems, so that they consider it an important opportunity should they be able to collaborate similarly with The Children's Psychological Health Center. At Califirnia's common cost of \$15,000 to \$40,000 or more <sup>a</sup> year, for a special education child who needs full time special education services and auxiliary intensive help, the savings for even one child's 12-year career of intensive services in special education can be substantial. The savings from one of the successes we have seen may equal the costs of the entire Cornerstone project with the 30 children helped so far.
+
+We have not yet seen any failures. The agency is showing measurable cognitive gains for our collaborative work which, according to their research, averages 20 to 28 points in independent WPPSI testing of the children in the Cornerstone program. The techniques are far more economical to use than we have found with the Lovaas method, which we also implement for some students. We have also seen the techniques transmitted to special education teachers as well as inexperienced therapists.
+
+I invite you to visit our project in action.
+
+Sincerely,
+
+JAYS. PARTIES, Ed.D. Senior Administrator Special Education
+
+#### MAJOR FEDERAL COURT FORENSIC ACTIVITIES:
+
+#### EVALUATIONS AND RECOMMENDATIONS HEARD IN FEDERAL COURT, HANNIBAL MISSOURI, November 15, 2001
+
+Under Dr. Kliman's leadership, a Children's Psychological Health Center team of five clinicians and two administrative staff has been at work since May 2, 2001 conducting a behavioral audit regarding the psychiatric conditions and the residential treatment of over 100 children (mostly ages 13 to 17) at Heartland Christian Academy, as requested by the Academy's general counsel.
+
+2001: Doe vs. Three Springs Treatment Center, Nashville, TN.
+
+2004: Does vs. L.K. Baliredy et al (An international child trafficking matter). Five days of deposition.
+
+<sup>2004</sup>Doc vs. State of New Mexico and Arthur Brokup.
+
+#### MAJOR STATE COURT CASES:
+
+#### Some cases of public health significance. concerning allegedly traumatized minors in care of governmental or institutional agencies:
+
+Does vs. OK Boys Ranch and State of Washington: 44 children in care at a state-licensed rehabilitation and care-related center were allegedly allowed to abuse each other while staff and therapists did not report harmful activities of which they knew, Dr. Kliman opined. The <sup>p</sup>laintiff children have to date all received settlements in four phases of this litigation over anine year period, with Dr. Kliman as the principal expert.
+
+York vs. Chaparral/Victor Treatment Facility. Orange County Superior Court. An eleven year old child severely and chronically molested by a residential treatment staff member was evaluated and an opinion given by Dr. Kliman concerning harm and how to rehabilitate the child as much as possible. Implications for standards of residential care are contained within the case.
+
+Carlson vs. Ray-Lars Home. Orange County Superior Court. Dr. Kliman evaluated and testified concerning a twelve year old boy who was allegedly molested by a father and had
+
+to rescue himself. The father's partner was negligent, Dr. Kliman opined. The judge agreed and awarded the child compensation for psychological damages.
+
+Does vs. Archdiocese of Los Angeles. Dr. Kliman was the lead psychiatric witness. The case settled after six days of his deposition testimony.
+
+Does vs. Salesian Order Western Region. Dr. Kliman was the lead psychiatric witness. The case settled after nine days of his deposition testimony and two days of trial.
+
+Does v South Dakota School for the Deaf. Multiple boys were molested by an older student. The state school administration was allegedly negligent and major psychological damages were claimed. Dr. Kliman served as the principal plaintiffs' expert on administrative liability issues and psychological damages. The case settled with major compensation for the plaintiffs during the time of jury deliberations.
+
+### CHILD PSYCHIATRIC EXPERT TESTIMONY:
+
+Dr. Kliman helped set legal precedents for the inclusion of psychiatric testimony in matters concerning wrongful death of a parent and loss of parental services, in both New York State and California. He has testified in over 275 cases including over 100 trials. A Federal Rule 26 list is available on request and on www.expertchildpsychiatry.com. His courtroom and deposition testimony experience includes cases of institutional negligence of children leading to psychological trauma, negligent care, loss of parental services due to wrongful deaths, psychological trauma as part of personal injury of adults and children, childhood molestation, sexual harassment, termination of parental rights, and disputed custody. Since 2000 about 30% of his forensic work has been requested by defense, about 70% by plaintiffs, with the defense tasks increasing markedly in recent years.
+
+Dr. Kliman's evaluations and testimony regarding 16 children negligently cared for and abused at The Kiwanis' OK Boys' Ranch, Olympia, WA, helped lead to settlements and awards, totalling \$25,000,000. Responding to disclosures in that case, many improvements have occurred in the publicly funded and licensed institutional care of children throughout the State of Washington, according to newspaper accounts.
+
+Dr. Kliman's evaluations and opinions, together with that of The Children's Psychological Trauma Center team led by Robert Wynne MFCC, led to record-making \$8,000,000 loss of parental and other services compensation for 17 bereaved subsistence-economy Alaskan Inupiat Native Americans (a. vs. Ryan Airlines, Anchorage, 1997).
+
+Principal expert regarding institutional negligence and psychological damages in Does vs. Rudolph Kos and the Diocese of Dallas, Dallas 1997. The Catholic Church of Dallas was held liable for institutional negligence, testimony concerning the need for major psychiatric treatment <sup>p</sup>lanning was accepted by the jury, and \$119,000,000—including punitive damages against the Church--was awarded to the 11 plaintiffs, by unanimous decision.
+
+## OTHER PUBLIC HEALTH ACTIVITIES AND RECOGNITION:
+
+Way In response to the mental health needs of families following recent massive firestorms, United printed and distributed 10,000 copies of "My Fire Story -- <sup>a</sup>Guided Activity Workbook for Children, Families and Teachers," co-authored with Edward Oklan, M.D. Copies can be obtained from Family Development Press, 1010 Sir Francis Drake Boulevard, Kentfield, CA 94960. The State America of Iowa purchased rights to reproduce 10,000 copies of "My Book about The Attack on - <sup>a</sup>Guided Activity Workbook for Children, Families and Teachers", published in 2001.
+
+During 1996 - 2002 Sophie Murvis Foundation, The Windholz Foundation, The Atkinson, Cadence Corporation, Irving Harris Foundation and The Stullsaft Foundations have recently awarded grants to Dr. Kliman as principal investigator for his Cornerstone Therapeutic Nursery project, serving seriously disturbed preschoolers in the San Mateo Office of Education.
+
+Presentations on The Cornerstone Therapeutic Nursery Project have been made by Dr. Kliman during 1997 through 2002 at the San Francisco Psychoanalytic Institute and the Seattle Institute for Psychoanalysis.
+
+Three documentary videotapes concerning Dr. Kliman's psychotherapies of disturbed children treated by him using this method in atherapeutic special education class are now available for scientific and educational purposes, parental permission having been gained. Such use requires <sup>a</sup>confidentiality agreement.
+
+Tape I: The Cornerstone Method.
+
+Tape II: Treatment of an Autistic Boy
+
+Tape 111: Unique Features of The Cornerstone Method
+
+As <sup>a</sup>pilot application of his techniques for preschoolers, Dr. Kliman opened a Cornerstone Therapeutic Nursery at the Salvation Army Shelter for homeless families in January 1998, Medical serving seven homeless families with preschool children. He is supervising the project weekly as Director of The Children's Psychological Trauma Center. Unedited videotapes of that project are available to scientists and educators with aconfidentiality agreement. The MI Institute has provided a psychology intern to conduct the treatment under Dr. Kliman's training and supervision. The California School of Professional Psychology has assigned a doctoral thesis candidate to Dr. Kliman's supervision to study the I.Q. rise phenomenon previously documented in Cornerstone therapies.
+
+Peer-reviewed publications of Dr. Kliman's work with children appear in Zelman, A: Interventions with High Risk Children, Jason Aronson "later by Kliman on Controlled Assessment of The Personal Life History Book Method for Children). Results of Dr. Kliman's Cornerstone Method are also reported extensively in that book, focusing on the I.Q. rise phenomenon.
+
+# Archive of Videotaped Seminars and Events:
+
+— Gilbert Kliman, M.D., Medical Director
+
+THE CHILDREN'S PSYCHOLOGICAL TRAUMA CENTER
+
+(A division of the Children's Psychological Health Center, Inc. )
+
+Archive of Videotaped Seminars and Events:
+
+### CONTINUING LEGAL EDUCATION TAPES:
+
+California MCLE credit is available to attorneys for study of these tapes. Unless otherwise indicated, Gilbert Kliman, M.D. was the sole or principal speaker. Contact Edith Lee at 415 474 0955 for MCLE credit fulfillment associated with study of these tapes.
+
+- 01. True and False Allegations of Sexual Molestations 1987. 1.5 hrs.
+- 02. Loss of Parental Services May 6th <sup>1992</sup>Elina Wayrynen and Gilbert Kliman, M.D. 2.0 hrs.
+- 03. Abuse in Institutions August 1' 1995, 2.0 hrs.
+- 04. Catastrophic Accidents with Lifetime Psychological Damage, December 5`<sup>h</sup> <sup>1995</sup>2.5 hrs.
+- 05. Evaluating Psychological Trauma in Catastrophic Accidents (Grosvenor Hotel San Francisco) 1996, 2.5 hrs.
+- 06. Loss of Parental Services (Holiday Inn),January 9`<sup>h</sup> 1996, 2.5 hrs.
+- 07. Loss of Parental Services, May 12th <sup>1993</sup>1.5 hrs.
+- 08. True and False Allegations of Sexual Abuse June 7'<sup>h</sup> 1993, 1.5 hrs.
+- 09. Catastrophic Psychological Traumas in Childhood, February 1994, 2.5 hrs.
+- 10. The Difficult Client February 27'<sup>h</sup> 1996, 2.5 hrs.
+- 11. The Difficult Client (at Wells Fargo). February 6'<sup>h</sup> 1996, 2.5 hrs.
+- 12. Evaluating the Validity of Recovered Memories: Perspective of aForensic Expert, February 29th 1996, 1.0 hr.
+- 13. How Small Clients Get Large Awards, Psychological Trauma in early childhood produces life time consequences in some cases. Defense and plaintiff considerations. 2.5 hrs.
+- 14. Giving Powerful Voices to Children in Court: I, March 20th 1998. Windle Turley, Esq. With Gilbert Kliman, M.D., 2.5 hrs.
+- 15. Giving Powerful Voices to Children in Court IL May 86' 1998, John Connelly, Jr. with Gilbert Kliman, M.D., 2.5 hrs.
+
+- 16. Giving Powerful Voices to Children in Court III,June 12th 1998, Marc June, Esq. With Gilbert Kliman, M.D., 2.5 hrs.
+- 17. Psychoanalysis and the Law: How Child Psychoanalysis Contributes to Justice for Children. Conference at the San Francisco Psychoanalytic Institute, March I<sup>n</sup> 1999, Introduction by Maureen Katz, M.D., Discussion by Katherine MacVicar, M.D., Gilbert Kliman, M.D., presenter. San Francisco Psychoanalytic Institute Extension Division. 1.5 hm.
+
+# The Children's Psychological Health Center Archive of Videotaped Seminars and Events:
+
+- Gilbert Kliman, M.D., Medical Director
+
+#### CLINICAL AND SCIENTIFIC TAPES:
+
+STARRED (\*) TAPES BELOW ARE A PRECIOUS ARCHIVE OF INFORMATION ABOUT PROBLEMS AND TREATMENT OF SEVERELY STRESSED CHILDREN. THEY ARE NOT FOR SALE OR COMMERCIAL DISTRIBUTION. THEY MAY BE STUDIED AT CPHC ON-SITE WITH ASSISTANCE OF OUR STAFF BY QUALIFIED RESEARCHERS, CLINICIANS, SPECIAL EDUCATION TEACHERS, ADMINISTRATORS OF NONPROFIT CLINICAL ORGANIZATIONS AND SCHOOLS FOR CHILDREN, SCIENTISTS AND STUDENTS OF RELEVANT DISCIPLINES BY APPOINTMENT AT CPTC HEADQUARTERS. CREDENTIALS, REFERENCES AND CONFIDENTIALITY AGREEMENT ARE REQUIRED COLLABORATIVE RESEARCH ARRANGEMENTS CAN BE CONTRACTED FOR WITH CONFIDENTIALITY AGREEMENTS AND LONG TERM USE OF THE TAPES.
+
+- Childhood Post Traumatic Stress Disorder (California Pacific Hospital Grand Rounds), 1992 New Theory of Post Traumatic Stress Disorder,Gilbert Kliman, M.D. December 4'<sup>h</sup> 1992, International Association of Child and Adolescent Psychiatry and Allied Disciplines, Fairmont Hotel, San Francisco. •3. Severe Psychological Trauma in very Young Children, March 23d <sup>1993</sup> \*4. Post Traumatic Stress Disorder: Child & Adult, September 27th <sup>1993</sup>
+- 5. Cost Effectiveness: Mental Health Services for Children,September 28<sup>6</sup> <sup>1993</sup>
+- 6. Preventive Child Psychiatry . Mc Aulev St Mary's October 1611'1993, \*7. New Theory of Post-Traumatic Stress Disorder, for Int. Association of Child and Adolescent Psychiatry July 25th <sup>1994</sup> \*8. Cornerstone Method Conference. Wells Fargo. January 30th <sup>1996</sup> \*9. Cornerstone Conference: Control - Mastery Group, San Francisco Psychoanalytic Institute. February 96 1996
+
+- 10. Conference on Childhood of Adolf Hitler.Control-MasteryGroup, San Francisco Psychoanalytic Institute, May 17 <sup>1996</sup>
+- 11. Orientation to the Personal Life History Book Method. CPTC & ACT For Mental Health, April 4th <sup>1997</sup>(two tapes) \*12. The Cornerstone Method: A Public Health Approach. National Association for Social Work and Psychoanalysis,Seattle. September 26 <sup>1997</sup> •13. New Theory of Psychological Trauma: Colloquium. San Francisco Psychoanalytic Institute,October 12`<sup>k</sup> <sup>1996</sup> \*14. Treatment of Severely Disturbed Preschoolers in their Public School Special Education Classrooms: A New Application of Intensive Psychotherapy. American Academy of Child and Adolescent Psychiatry. \*15. Treatment of an Autistic Boy. the Cornerstone Method \*16. The Cornerstone Therapeutic Nursery Method \*17. The Cornerstone Method: Unique Features
+- 18. Investing in our Futures: Rotary Club: About the Cornerstone Method, December 9th <sup>1997</sup>Robert Denebeim, Esq. With Gilbert Kliman, M.D.
+- 19. Salivation Army Cornerstone Program: Channel 4 News. Linda fl Reporter.
+- 20. Gilbert Kliman M.D. on Channel 4 News, April 22d 1998. LindaIt Reporter.
+- 21. Orientation to The Personal Lie History Book October 13<sup>6</sup> <sup>1998</sup>(three tapes) '22. The Psychoanalytic Psychotherapy of aFour Year Old Boy, 1999. An ongoing archive made with generous permission of the child's family, now totaling over 25 hours. This child has had severe stressors in his life, and suffers behavioral and overanxious symptoms. He has impulse dyscontrol, attentional deficits, and expressive language difficulties from which he can be seen to be recovering. Two excerpted tapes have been created to illustrate features of the child's pathology, and of the response to interpretive aspects of treatment. Gilbert Kliman, M.D. is the psychoanalyst, and the treatment is conducted three times aweek, with parent guidance every two weeks. The videographer is in the room. This may be the only existing video archive of achild analysis conducted by a certified child psychoanalyst. •23. Cornerstone Treatment Archives: 1995-2008. Ongoing archive of intensive in-classroom treatment of seriously disturbed preschoolers, within their public special education classrooms in San Francisco and San Mateo, Shelters for homeless families in San
+
+Francisco and Seattle, private therapeutic preschool in San Francisco, and Cornerstone Argentina
+
+- 24. Thirty four year follow-up of aCornerstone Treated autistic child, now recovered. Presented at The San Francisco Psychoanalytic Institute, Child Analysis Study Group, 2001. Permission for public viewing granted by the patient. Excerpts may be viewed on www.childrenspsycholoeical.org or the entire video obtained from <sup>g</sup>ilbertkliman2008(4)gmail.com
+
+•25 Orientation of the Family Services Center of County. Four days in December, 2007, in Seattle. Six DVD's.
+
+# Scientific and Educational Video Archives under Dr. Kliman's supervision:
+
+With parental permission, The Children's Psychological Health Center, under Dr. Kliman's leadership, is collecting unedited treatment documents of aspecial method of treatment in areal life space, called "The Cornerstone therapeutic preschool method." Now totaling over 200 video archive hours, eight different California therapists working with various educator teams have recorded their Cornerstone therapeutic preschool method work. Beginning in 1995, this archive started with Gilbert Kliman, M.D. working for <sup>a</sup>year as daily in-classroom therapist in apublic special education school. He was assisted by Leanne Runyan and Gail as the teachers at the San Mateo Early Childhood Education Center, a preschool specialeducation facility of The County of San Mateo. A second team under his supervision included work at The San Francisco Unified School District (Vanessa Vigilante and Esther Kronenberg). Third and fourth teams were at The Salvation Army Gateway Shelter (Vanessa Vigilante as therapist and Lynda Byrd as teacher, Deanna Reardon as therapist and Lynda Byrd as teacher). A fourth was at The Cadence Cornerstone Site at Mt. Pleasant School, San Jose (ICarita Hummer, therapist and Kathy Krall, teacher). Fifth team therapy was provided by Jane Christmas. The sixth team therapists was Dr. Miquela Hope, the seventh Molly Franklin, MFT. All have been extensively videotaped carrying out the method. An eighth team was assembled in late 2002, when Linda Hirshfeld Ph.D. joined as Fellow in Cornerstone Therapy. In 2001 Mike McDonald, Ed.D. became Special Education Director of Cornerstone School. All the treatments are have been under principal supervision of Dr. Kliman with additional supervision by Mali M.D., Myrna Frankel, Ed.D., and Jan Baeuerlen, M.D. Linda Hirshfeld, Ph.D. of the Ann Center is conducting the archival work for her Cornerstone Services.
+
+<sup>A</sup>professional researcher/ training confidentiality agreement is required to study this archive.
+
+SAOK Private Forensic 7-I3.04\CV\PPA CVs Gilbert Kliman CV ppa 06 02 08.doc

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marker2/court-doe-102-v-epstein/EFTA02738953/EFTA02738953.md

@@ -0,0 +1,241 @@
+# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 3,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5, CASE NO.: 08-CV-80381-MA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+CASE NO.: 08-CV-80232-MARRA
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 7,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+C.M.A., CASE NO.: 08- CV-8081 I -MARRA/
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08- CV-80993-MARRA
+
+JANE DOE,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN, et al.,
+
+Defendant.
+
+DOE II, CASE NO.: 08-CV- 80469-MARRA
+
+Plaintiff, vs.
+
+CASE NO.: 08- CV-80893-MARRA
+
+JEFFREY EPSTEIN et al.,
+
+Defendant.
+
+JANE DOE NO. 101, CASE NO.: 08- CV-80591-MARRa
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 102, CASE NO.: 08- CV-80656-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+## PLAINTIFFS JANE DOES 2-7'S RESPONSE TO DEFENDANT'S MOTION TO COMPEL AND/OR IDENTIFY PLAINTIFFS IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY, OR ALTERNATIVELY, MOTION TO DISMISS "SUA SPONTE", WITH INCORPORATED MEMORANDUM OF LAW
+
+Plaintiffs, JANE DOES 2-7, hereby serve their Response to Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss "Sua Sponte", With Incorporated Memorandum of Law, and state as follows:
+
+- I. The lawsuits filed by JANE DOES 2-7 involve private, intimate facts pertaining to their own childhood sexual abuse and exploitation by Defendant Jeffrey Epstein.
+
+2. Jane Does 2-7 filed their suits under a pseudonym' to prevent public disclosure of the private, highly sensitive and intimate facts pertaining to their sexual assaults, and the public association of their identities with Defendant Epstein and these assaults.
+
+3. Dr. Gilbert Kliman,' a well-known forensic psychiatrist with an expertise in the field of child trauma, has met with and evaluated each of Jane Does 2-7 and opined that public disclosure of their real names would create a substantial risk to them of further psychological harm. See Exhibit "A", Declaration of Gilbert Kliman. M.D.
+
+4. Dr. Kliman opines as follows:
+
+Releasing names of the plaintiffs to the public will reenact experiences of powerlessness and helplessness in the face of a boundary violation. Repetition and reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of posttraumatic stress disorder trauma. In effect, release of their identity and public intrusion into their personal life represents a reenactment of the shame of sexual traumatization. Repetition and reenactment are central pathologies that afflict sexual trauma survivors.
+
+Victims of sexual abuse often rely upon some form of dissociation, splitting or denial, as a defensive means to manage overwhelming affects associated with the sexual trauma. Each of the plaintiff girls has employed some variation of this defense, both during the massages and then subsequently following disclosure of the abuse. Primitive, maladaptive responses of this nature will become additionally reinforced as a result of public disclosure.
+
+Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, is that the trauma was associated with human design factors (such as cruel intention to do harm, rape, torture). Trauma of this origin has a tendency to produce more "severe or long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 4.64). A policy of deliberate revelation of the names of the victims would reinforce the sense of design, pattern and policy of human intentions.
+
+It is my opinion, with a reasonably high degree of medical certainty that the defense motion to allow public disclosure of the plaintiffs' identity is clinically
+
+<sup>1</sup> Defendant and his counsel are aware of the real names of Jane Does 2-7.
+
+<sup>2</sup> A copy of the curriculum vitae of Dr. Gilbert Kliman is attached hereto as Exhibit "B".
+
+and ethically a wrongful plan. The act of revealing their identity against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering an aggravation of existing diagnostic concerns. It is more probable than not that releasing personal identities will an exacerbation and magnification of symptoms lending to increased risk of revictimization and retraumatization.
+
+S Exhibit "A", 13-15, 21
+
+5. Given the private nature of the allegations in this lawsuit and the serious risk of harm to the mental health of Jane Does 2-7 if a public disclosure of their identities were required, Jane Does 2-7 should be permitted to continue using a pseudonym in this lawsuit.
+
+6. Notably, in one of the cases consolidated for purposes of discovery, Jane Doe v. Jeffrey Epstein, Case No. 08-80893, this Court recognized the harm likely to result from public disclosure of the victims' identities in these cases, and allowed the Plaintiff in that case to "proceed in this action under the pseudonym 'Jane Doe' ", by Order dated October 6, 2008.
+
+7. Jeffrey Epstein sets forth no facts to support his bare contention that Jane Does 2- 7 use of a pseudonym in these proceedings interferes with his "constitutional due process right." Ste Motion to Compel, p. 3. Defendant and his counsel know the identities of these Plaintiffs.
+
+8. Defendant also requests the Court's permission to use the real names of Jane Does 2-7 in various third-party subpoenas for discovery purposes. Defendant does not identify any of the entities or persons to whom he intends to send subpoenas. An order granting the relief requested without limitations would essentially nullify Jane Does 2-7's right to proceed anonymously. Jane Does 2-7 therefore object to the issuance of third-party subpoenas, and submit that Defendant can obtain the discovery he seeks by alternative means that will preserve the confidentiality of the Jane Does 2-7's identities.
+
+9. If this Court were to permit third party subpoenas or records custodian depositions using the existing captions and identifying Jane Does 2-7 in the body of the subpoena by their names, due to publicity surrounding the Defendant's crimes, then Jane Does 2- 7 would effectively be revealed as abuse victims in these cases against Defendant Epstein. Any subpoenas or notices to third parties therefore should not disclose the type of action or the Defendant's identity. There are alternatives which would preserve Jane Does 2-7's anonymity and be more efficient and cost-effective at the same time. For instance, Defendant can obtain records from various non-party sources through Plaintiffs' counsel, who can certify that they have obtained the records through authorizations signed by Jane Does 2-7. Another means to obtain non-party records concerning Plaintiffs is the appointment of a special =, who would verify authenticity and completeness of the records.
+
+10. Finally, Jeffrey Epstein's request that this Court order a "sua sponte" dismissal is illogical. Sua sponte means "[w]ithout prompting or suggestion; on its own motion." Black's Law Dictionary 1437 (7th ed.1999). Thus, the definition of sua sponte does not fit these circumstances, because the Court is being prompted by Epstein's Motion. Velchez v. Carnival Corp" 331 F.3d 1207 (11th Cir. 2003). In any event, there is no basis or authority to support a dismissal of these cases.
+
+WHEREFORE, Plaintiffs Jane Does 2-7 respectfully request that (i) this Court deny Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss "Sua Sponte", in its entirety; (ii) Plaintiffs Jane Does 2-7 be permitted to continue using their pseudonyms in this litigation; (iii) this Court order that records from non-parties relating to Jane Does 2-7, including medical and employment records, only be obtained through Plaintiffs' counsel by means of signed authorizations that do not include the caption or identify Epstein as the party seeking records, or alternatively, appoint a special to obtain the records, who would verify authenticity and completeness of the records; and (iv) all other relief this Court deems just and appropriate.
+
+# MEMORANDUM OF LAW
+
+## 1. PLAINTIFFS JANE DOES 2-7 SHOULD BE PERMITTED TO PROCEED ANONYMOUSLY IN THIS CASE DUE TO THE SENSITIVE, PRIVATE NATURE OF THE UNDERLYING FACTS AND THE RISK DI' PSYCHOLOGICAL HARM TO THE PLAINTIFFS
+
+Federal courts permit a party to proceed under a pseudonym when special circumstances warrant anonymity. See, e.g., Roe v. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 685-87 (11th Cir.2001); Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1068-69 (9th Cir.2000); James v. Jacobson, 6 F.3d 233, 238-39 (4th Cir.1993); EW v. New York Blood Center, 213 F.R.D. 108, 110-12 (E.D.N.Y.2003); Javier v. =-Botello, 211 F.R.D. 194, 196 (W.D.N.Y.2002); Doe v. , 105 F.Supp.2d 40, 43.44 (E.D.N.Y.1999); Doe v. United Servs. Life Ins. Co., 123 F.R.D. 437, 439 (S.D.N.Y.1988). Sexual assault victims are a paradigmatic example of those entitled to a grant of anonymity. See Doe No. 2 v. Kolko, 242 F.R.D. 193 (ED. N.Y. 2006); Doe v. Blue Cross & Blue Shield United of Wisc., 112 F.3d 869, 872 (7th Cir.1997) ("fictitious names are allowed when necessary to protect the privacy of ... rape victims, and other particularly vulnerable parties or witnesses"); see also Doe v. City of Chicago, 360 F.3d 667, 669 (7th Cir. 2004).
+
+The decision whether to allow a plaintiff to proceed anonymously is within the court's discretion. See Aware Woman Or., 253 F.3d at 684; Javier, 211 F.R.D. at 195; EW, 213 F.R.D. at 110. As set forth above, this Court exercised its direction in one of the consolidated cases, Jane Doe v. Jeffrey Epstein, Case No. 08-80893, to allow a plaintiff to proceed under the pseudonym "Jane Doe" in an Order dated October 6, 2008.
+
+Courts will permit a party to proceed under a pseudonym where "the party's need for anonymity outweighs prejudice to the opposing party and the public's interest in knowing the party's identity." Does I Thru XXIII, 214 F.3d at 1068; see Javier, 211 F.R.D. at 195; EW, 213 F.R.D. at 111; As set forth herein, the balancing test in this case weighs in favor of permitted plaintiff to continue to proceed anonymously:
+
+> In undertaking this balance, courts have considered such facts as (1) whether the plaintiff is suing the government or a private person; (2) whether the plaintiff would be compelled to disclose intimate information; (3) whether plaintiff would be compelled to his or her intention in engage in illegal conduct, thereby risking criminal prosecution; (4) whether the plaintiff would risk injury if identified; (5) whether the party defending against a suit brought under a pseudonym would thereby be prejudiced; (6) the ages of the parties whose identity is to be suppressed; (7) the extent to which the identity of the litigant has been kept confidential; (8) whether, because of the purely legal nature of the issues presented or otherwise, there is an atypically weak public interest in knowing the litigants' identities; and (9) the public interest in guaranteeing open access to proceedings without denying litigants access to the justice system.
+
+Doe v. Del Rio 241 F.R.D. 154, 157 (S.D. N.Y. 2006)
+
+The public has a strong interest in protecting the identities of sexual assault victims so that other victims will not be deterred from reporting such crimes. See Doe v. , 202 F.R.D. 173, 176 (E.D.Pa.2001) (granting anonymity to sexual assault victim); Doe No. 2 v. Kolko, 242 F.R.D. 193 (E.D. N.Y. 2006). That is particularly true in these consolidated cases where there are numerous victims with similar claims. Although these cases have gained considerable media attention, there appears to be little public interest in knowing the specific identity of each of the victims.
+
+With regard to the second factor, courts have granted anonymity to protect against disclosure of a wide range of issues involving matters of the utmost intimacy, including sexual assault. See, e.g., Aware Woman Ctr., 253 F.3d at 685 (abortion); EW, 213 F.R.D. at II I (infection with hepatitis B); Doe v. 202 F.R.D. 173, 176 (E.D.Pa.2001) (sexual assault victim); , 105 F.Supp.2d at 42 (sexual assault victim); WGA v. Priority Pharmacy, Inc., 184 F.R.D. 616, 617 (E.D.Mo.1999) (status as AIDS patient); Doe v. United Servs. Life Ins. Co., 123 F.R.D. 437, 439 (S.D.N.Y.1988) (sexual orientation); see also Blue Cross, 112 F.3d at 872 (recognizing rape victims as entitled to anonymity). It cannot be reasonably denied that a person's sexual history — especially during their childhood — is an intimate fact. When the childhood sexual history includes criminal sexual contact by an adult, the facts are even more intimate and personal. In the electronic age in which we live, these concerns are heightened. As federal courts have recognized in this context, it is now possible to "determine whether a given individual is a party to a lawsuit in federal court anywhere in the country by the simplest of computer searches, to access the docket sheet of any such case electronically, and ... that entire case files will be accessible over the Internet." Doe v. City of New York, 201 F.R.D. 100, 102 (S.D.N.Y.2001) (denying anonymity where any injury was purely reputational and case did not involve private or intimate matter); see EW, 213 F.R.D. at 112-13.
+
+As Dr. Kliman explains in his Declaration, disclosure of Jane Does 2-7's identities will place these Plaintiffs "at-risk of having their personal lives scrutinized by friends, extended family, spouses, children, fellow students, employers and fellow employees, the media and general public. This type of exposure humiliates many victims and represents another betrayal of trust. Public exposure places the plaintiff's at further risk of stigmatization, shame and retraumatization." See Exhibit "A" at 1 3. Dr. Kliman also finds it of no consequence that some of the plaintiffs are now legally adults in that "[d)ue to traumatization the plaintiffs are arrested in their development, and even those who are now legally adult are arrested in part to adolescent
+
+aspects of psychology." Id. at 1 4
+
+The policy of protecting victims of sexual misconduct from undue embarrassment and disclosure of their private affairs is firmly established in Fed.R.Evid. 412. The protections of Rule 412 are designed to "encourage victims of sexual misconduct to institute and participate in legal proceedings against alleged offenders." (Committee Notes to 1994 Amendment). Likewise, many states in this country, including Florida and New York, have similarly enacted laws to protect the anonymity of sexual assault victims. See Fla. Stat. §§794.024, 794.026 (2008); N.Y. Civil Rights Law § 50-b (McKinney 2009). In 1994, the Florida Legislature passed The Crime Victims Protections Act. The legislative stated purpose for the Act was "to protect the identity of victims of sexual crimes." Fla. AGO, 2003-56, 2003 WL 22971082 (Dec. 15, 2003). Under §794.024, Florida Statutes, court records that identify the name and/or address of a victim of a sexual crime are presumed to be confidential and exempt from public access. Id. Similarly, upon approving New York's rape shield law, then Governor Mario stated, "sexual assault victims have unfortunately had to endure a terrible invasion of their physical privacy. They have a right to expect that this violation will not be compounded by a further invasion of their privacy." 1991 McKinney's Sessions Laws of N.Y., at 2211-2212 (quoted in Deborah S. v. Diorio, 153 Misc.2d 708, 583 N.Y.S.2d 872 (N.Y.Ciry Civ.Ct.1992)); see also Coker v. Georgia, 433 U.S. 584, 597, 97 S.Ct. 2861, 53 L.Ed.2d 982 (1977) ("Short of homicide, [rape] is the ultimate violation of self').
+
+As to the fourth factor of risk injury, Dr. Kliman has evaluated Jane Does 2-7, and has concluded that the childhood sexual abuse at issue has caused features of post-traumatic stress disorder (PTSD), including shame, guilt, helplessness, and powerlessness. See Exhibit "A" at III 4-7. Dr. Kliman further states, "it is more probable than not that releasing personal identities will an exacerbation and magnification of symptoms lending to increased risk of revictimization and retraumatization." Id. at 1 21. Thus, this is not a case analogous to those cited by defendant in which the plaintiffs were merely at risk of "personal embarrassment." Instead, there is a genuine and immediate risk of psychological harm.
+
+None of the cases cited by Defendant where courts denied a plaintiff's request for anonymity involved victims of childhood sexual assault or evidence of emotional or psychological harm that would result from disclosure of the plaintiff's identity. See Doe v. Hartz, 52 F.Supp.2d 1027 (N.D.Iowa 1999); Doe v. Shakur, 164 F.R.D. 359 (E.D.N.Y.1996); Doe v. Bell Atlantic Bus. Sys. Servs., 162 F.R.D. 418 (D.Mass.1995); Doe v. Univ. of Rhode Island, 28 Fed.R.Serv.3d 366, 1993 WL 667341 (D.R.I. Dec. 28, 1993).
+
+As to the factor of prejudice, the Defendant does not identify how his ability to conduct discovery or impeach Jane Does 2-7's credibility has been or will be impaired if these Plaintiffs are permitted to proceed under a pseudonym. See EW, 213 F.R.D. at 112, M, 105 F.Supp.2d at 44-45. Other than the need to make redactions and take measures not to disclose these Plaintiffs' identities, Defendant will not be hampered or inconvenienced merely by Plaintiffs' anonymity in court papers. As set forth above, Defendant already knows their true identities. See Aware Woman Center, 253 F.3d at 687 (no prejudice where plaintiff offered to disclose her name to defendant); EW, 213 F.R.D. at 112; , 105 F.Supp.2d at 44-45.
+
+# II. DEFENDANT SHOULD NOT BE PERMITTED TO USE THE REAL NAMES OF JANE DOES 2-7 IN THIRD-PARTY SUBPEONAS EXCEPT FOR THOSE ISSUED TO PERSONS WHOM PLAINTIFFS HAVE ALREADY DISCLOSED THEIR SEXUAL ABUSE
+
+As for the use of Jane Does 2-7's real names in subpoenas issued to non-parties, a party may obtain discovery of any non-privileged matter that is relevant to a claim or defense of any party. Fed.R.Civ.P. 26(b)(1). However, a district court may limit discovery "for good cause shown" by making "any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense," including that the discovery not be had or that it be had only by a method other than that selected by the party seeking discovery. Fed.R.Civ.P. 26(c). Jane Does 2-7 have articulated a specific and substantial harm from disclosure of their identities.
+
+If this Court were to permit Defendant to issue third-party subpoenas containing Jane Doe 2-7's real names, the identity of the Defendant, and/or facts pertaining to the nature of the case to whomever Defendant wants, it would be akin to requiring these Plaintiffs to use their real name in the pleadings. Instead, Jane Does 2-7 propose to voluntarily execute authorizations (which would not contain the case names or the identity of the Defendant) to allow Defendant to obtain education, employment, and medical records to be used for purposes of this litigation only.<sup>3</sup>Alternatively, Defendant can obtain the records through a special who would verify authenticity and completeness of the records. Either of these approaches would not only place Jane Does 2-7 at less risk of psychological harm, but would also be more cost-effective and efficient.
+
+# CONCLUSION
+
+Based on the foregoing, Plaintiffs Jane Does 2-7 respectfully request that Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss "Sua Sponte" be denied in its entirety, and that Plaintiffs Jane Does 2-7 be permitted to continue using their pseudonyms in this litigation. Additionally, to avoid public disclosure of the Plaintiff's identities in non-party records discovery, Plaintiffs Jane Does 2-7 request that such
+
+<sup>3</sup> Defendant and Plaintiff have previously agreed that education records can be obtained in this
+
+discovery be obtained either through Plaintiffs' counsel by means of written authorizations, or by the appointment of a special
+
+Dated: June 8, 2009
+
+Respectfully submitted,
+
+By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) ssm@sexabuseattomey.com Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattomey.com MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs Jane Doe Nos. 2-7 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: (305) 931-2200 Fax: (305) 931-0877
+
+## CERTIFICATE OF SERVICE
+
+I hereby certify that on June 8, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+/s/ Adam D. Horowitz
+
+# SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida
+
+Jack Alan Goldberger, Esq.
+
+iaoldberger@agwpa.com
+
+Robert D. Critton, Esq.
+
+rcritton@bc1claw.com
+
+James
+
+bedwards@rra-law.com
+
+Isidro Manuel
+
+isidroaarcia@bellsouth.net
+
+Jack U
+
+ioh@searcylaw.com
+
+Katherine Warthen Ezell
+
+KEzell@podhurst.com
+
+Michael James Pike
+
+MPike@bciclaw.com
+
+Paul G. Cassell
+
+cassellp@law.utah.edu
+
+Richard Horace Willits
+
+lawyenvillits@aol.com
+
+Robert C. Josefsberg
+
+rjosefsberg@podhurst.com
+
+/s/ Adam D. Horowitz