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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 | PERSONAL INJURY PERSONAL INJURY Habeas Corpus: t n 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
+
+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 recor 4 4 identified on the following Service List in the manner specified by CM/ECF on this ay of May, 2009
+
+Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400
+
+Doe 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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+## 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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+## 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 14th 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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+**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 15th Judicial Circuit is "closed" in
+
+accordance with the United States Attorney's Office ("USAO") Non-Prosecution Agreement ("NPA") and until the NPA expires.
+
+Moreover, EPSTEIN was indicted by a grand jury in or around July 2006. See Exhibit "A". The Non-Prosecution Agreement is part of the record in connection with that indictment, which is signed by the State Attorney of the 15th Judicial Circuit in and for Palm Beach County, Florida ("SAO"). In fact, the NPA acknowledges the investigation performed by the SAO. Further, the USAO was present at the Plea hearing whereby the NPA was made part of the record. Thus, there is no question that a parallel criminal matter exists in that the SAO's case remains open and the NPA lives along side it, which places EPSTEIN under great 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, 2006 WL 3392207 (S.D. Fla. 2006), citing United States v. Lot 5, Fox Grove, 23 F.3d 359 (11th Cir. 1994). In Ventura, a stay was entered where a Defendant was confronted with issue of waiving his 5th Amendment Privilege or to loose a civil case by way of motion for summary judgment. Id. Here, EPSTEIN is not requesting a mandatory stay. EPSTEIN only asks that this court recognize that "special circumstances" exists in this matter and enter a stay in the "interests of justice" and only for a specified period of time (i.e., after the NPA expires). See 1.122 Securities and Exchange Commission, 755 F.Supp. 1018, 1019 (S.D. Fla. 1990)(Defendant was in precarious position while being subject to criminal investigation and reasoning that compelling Defendant to speak by ordering an accounting of alleged illicit funds would directly
+
+Page 6
+
+impinge his right against self-incrimination). The court found it appropriate to grant the request for stay. (Emphasis Added).
+
+Citing to U.S. v. Lot 5, Fox Grove supra, the Southern District Court, Florida, in Ventura v. Brosky 2006 WL 3392207 (S.D. Fla. 2006), stated —
+
+The Eleventh Circuit has also created a test for these circumstances, stating that where there exists a concurrent civil and criminal proceeding, a court must stay a civil proceeding pending resolution of a related criminal prosecution when "special circumstances" so require in the "interests of justice."
+
+(Bold emphasis added). au also United States v. Kordel, 397 U.S. I, 12 & n. 27, 90 S.Ct. 763, 769-70 & n.27 (1970). The Ventura Court went on to state that "situations where a defendant in both criminal and civil proceedings must choose whether to waive his privilege against selfincrimination or to lose the civil case in summary or default judgment proceedings have met this test's burden and warrant a stay." Id. The Ventura court granted the stay. Here, the 15'h Judicial Circuit action lives along with the NPA.
+
+In making a decision to enter such a stay, the court may consider the following factors:
+
+- (I) the interests of the Plaintiffs in proceeding expeditiously with litigation, or any aspect of it, and the potential prejudice of Plaintiff to the delay;
+- (2) the burden which any particular aspect of the proceedings may impose on the defendant;
+- (3) the convenience of the court in the management of its cases, and the efficient use of judicial resources;
+ - (4) the interests of persons not parties to the civil litigation; and
+ - (5) the interest of the public in the pending civil and criminal litigation.
+
+Page 7
+
+See U.S. v. Pinnacle Ouest International, 2008 WL 4274498 (N.D. Fla. 2008).
+
+First, in applying the above factors, the Plaintiff in the instant matter will not be prejudiced simply by claiming a delay in time. Second, the burden is far greater on the EPSTEIN if he is forced to waive his 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 19th day of February, 2009.
+
+
+
+![]()
+
+### 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)
\ No newline at end of file
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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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new file mode 100644
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@@ -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
\ No newline at end of file
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diff --git a/marker2/court-doe-102-v-epstein/EFTA02738817/EFTA02738817.md b/marker2/court-doe-102-v-epstein/EFTA02738817/EFTA02738817.md
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@@ -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 NUMBER05-368 | | DATE/TIME RECOVERED10-20-2005 | | PROPERTY NUMBER (Leave Blank)05-1024 | | |
+|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------|----------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------|--------------|--|
+| ADDRESS WHERE PROPERTY IMPOUNDED258 FL-Bullo | | | | | | |
+| 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.Eostein Seff | ADDRESS | Street | City | Zip | PHONE NUMBER | |
+| ADDT IN SUSPECT / D.O.B. | ADDRESS | Street | City | Zip | PHONE NUMBER | |
+| SPECIAL INSTRUCTIONS | | | FOUND PROPERTY 05-368 | DATE/TIME RECOVERED10:20-05 | PROPERTY NUMBER (Leave Blank)05-1024 | BIN NUMBER (Leave Blank)06b |
+|-------------------------------------------|----------------------------------------|-------------------------------------------------|----------------------------------------|
+|-------------------------------------------|----------------------------------------|-------------------------------------------------|----------------------------------------|
+
+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.Fostin J.Ff | 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 | | lab |
+| INCIDENT/CITATION NUMBER05-368 | DATE/TIME RECOVERED10-20-05 | PROPERTY NUMBER (Leave Blank)05-1024 | BIN NUMBER (Leave Blank) | | | |
+| ADDRESS WHERE PROPERTY IMPOUNDED258 El 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.Eostein, Jeff | 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
+
+| 54 | 1 | Power cord to CPU (#53) | Return |
+|-----------|---|-------------------------------------------------|--------|
+| 55 | 1 | CPU from office off Kitchen (Hall & Robinson) | Return |
+| 56 | 1 | Power cord to item #55 | Return |
+| 57 | 3 | CD's Arm #55-57 from Office off Kitchen Detroit | Return |
+| 58 | 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
+
+| (ab) |
+| INCIDENT/IDENTIFICATION NUMBER05- | DATE/TIME RECOVERED10 2005 14/0 | PROPERTY NUMBER (Last Blank)05-1024 | 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. / RESTAURANT | ADDRESS | Street | City | Zip | PHONE NUMBER |
+| ADDITING SUSPECT / D.O.B. | ADDRESS | Street | City | Zip | PHONE NUMBER |
+| SPECIAL INSTRUCTIONS | FOUND PROPERTY 80 DAYS Return |
+| | | | Return |
+| | | | Return |
+| | | | Return |
+| | | | Return |
+| | | | Return |
+| | | | Return |
+| | | | 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.
+
+DATE \_\_\_\_\_ SIGNATURE \_\_\_\_\_ ID# \_\_\_\_\_ UNIT \_\_\_\_\_
+
+RECEIVED BY *AB 8338* REASON *6* DATE/TIME RECEIVED *10-20-05 1500 kg*
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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
+
+
+
+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, 20091
+
+[REDACTED]
+
+---
+
+1 We will supplement this list as necessary.
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diff --git a/marker2/court-doe-102-v-epstein/EFTA02738827/EFTA02738827.md b/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
\ No newline at end of file
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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-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 10th 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
\ No newline at end of file
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diff --git a/marker2/court-doe-102-v-epstein/EFTA02738848/EFTA02738848.md b/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
\ No newline at end of file
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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
\ No newline at end of file
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new file mode 100644
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@@ -0,0 +1,115 @@
+## 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
\ No newline at end of file
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diff --git a/marker2/court-doe-102-v-epstein/EFTA02738861/EFTA02738861.md b/marker2/court-doe-102-v-epstein/EFTA02738861/EFTA02738861.md
new file mode 100644
index 0000000000000000000000000000000000000000..c3117fa01da2cc9745fd0e03d5e70e09eb5d71ee
--- /dev/null
+++ b/marker2/court-doe-102-v-epstein/EFTA02738861/EFTA02738861.md
@@ -0,0 +1,143 @@
+## 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
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+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
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+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:
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+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?
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+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
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+### 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:
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+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:
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+[A] blanket assertion of the privilege is an inadequate basis for the issuance of a stay. Rather, a court must stay a civil
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+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.
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+Court-Appointed Receiver of Lancer Mgt. Group LLC v. Lauer, 2009 WL 800144 (S.D. Fl. Mar. 25, 2009) (Marra, J.).
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+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.
+
+&# 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.").
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+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
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+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.
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+&# 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 "identified victims" under the NPA, this contractual provision would not apply.B. Additional Factors to Consider in Balancing the Prejudice to the Parties If the Court is persuaded that the negative inference drawn from Epstein'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 "special circumstances" warranting the imposition of a stay "'to prevent a party from suffering substantial and irreparable prejudice." Securites and Exchange Comm'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'/ citations omitted).
Examples of "special circumstances" 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.
Incendy at 956 (citing United States v. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Comm'n v.=, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o 'special circumstances' 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.").
No "special circumstances" 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
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.
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
investigation where no indictment had been returned. The district court denied the motion, noting that while "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.") (citations omitted).
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' 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;With respect to the other "special circumstances" 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's personal publicist distributed stories to the press impugning the credibility of the victims and other witnesses and averring that the victims' 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
Unlike and Incendy, Epstein also has not been criminally indicted. In some districts, this alone is virtually dispositive. See, e.g., Sterling Nat'l Bank v. A-1 Hotels Internat'l, 175 F. Supp. 2d 573, 576-77 (S.D.N.Y. 2001) ("district courts in this Circuit `generally grant the extraordinary remedy of a stay only after the defendant seeking a stay has been indicted.'" (quoting Citibank, N.A. v. 1993 WL 481335 \*1 (S.D.N.Y. Nov. 18, 1993) (add'/ citations omitted). As one court explained:
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's Fifth Amendment rights, and the likely extent and timing of the criminal litigation.
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'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
to unseal the victims' names so that he may make use similar press efforts to impugn their credibility.
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 "extraordinary" remedy of a stay is inevitably much reduced.
Sterling Nat'l Bank, 175 F. Supp. 2d at 577 (internal citations omitted).
The First Circuit has noted that the decision whether to grant a stay "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." Microfinancial, supra, 385 F.3d at 78. Epstein's case is more idiosyncratic than most.
As the Court aptly noted in its Order denying Epstein's first motion to stay the civil proceedings, Epstein has not been indicted and there are no criminal proceedings pending against him.' The resurrection of criminal proceedings against Epstein lies entirely within Epstein'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'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
&# x27;Epstein points to provisions requiring him to maintain certain evidence "inviolate" 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'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's docket, at the insistence of the United States, because it fully halted its investigation in accordance with the terms of the NPA.
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).
Epstein argues that because he is seeking a finite period of delay — until the time that he asserts that the NPA "expires" — 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's proposed "expiration date," 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 "expiration" 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 "potentially indefinite," as Sterling Bank warns. If the U.S. Attorney's Office were to proceed criminally, the litigation would likely be very lengthy, and would result in an even greater delay to the plaintiffs?
&# x27;The United States also notes that this finite termination to Epstein's exposure to potential criminal consequences is illusory. The NPA addresses only certain victims identified during the course of the government'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,
The factors to consider include: "(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." Microfinancial, 385 F.3d at 78 (citations omitted).
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 "crime victim" with the "right to full and timely restitution" and the "right to proceedings free from unreasonable delay." 18 U.S.C. § 3771(a)(6) & (7). As noted above, one of the purposes of the NPA was to provide these rights to victims identified in the Government's investigation. Thus, this factor weighs more heavily for the plaintiffs than in the average civil dispute as it embodies both the plaintiffs' and the public'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
whichever is longer. 18 U.S.C. § 3283. Thus, for Epstein (or any other person accused of sexually abusing children) to "wait out" any chance of criminal liability, the court would have to stay civil litigation until all of the plaintiffs have died.
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's assets while the matter is stayed. On the other hand, while the potential harm to the defendant normally weighs in the defendant's favor, in this case, Epstein has significant control over whether the criminal investigation remains in abeyance and whether criminal charges are ever filed.
CONCLUSION In accordance with the Court's Order, the United States hereby submits that it is not aware of any "special circumstances" that warrant staying all of the civil cases pending the "expiration" of the NPA.
Respectfully submitted,
R. ALEXANDER ACOSTA UNITED STATES ATTORNEY
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
CERTIFICATE OF SERVICE 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's website, counsel for all parties are able to receive notice via the CM/ECF system.
ti a lVILLAFASA Assistant United States Attorney Villqfafia
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