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marker2/court-doe-v-epstein-80469/EFTA02750312/EFTA02750312.md

@@ -0,0 +1,173 @@
+•
+
+JANE DOE II
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, and
+
+Defendants.
+
+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Mar. 24, 2009
+
+STEVEN M. LARIMORE CLERK U.S. DIST. CT. S. O. OF FLA. • MIAMI
+
+## 09-80469-Civ-RYSKAMP/VITUNAC
+
+#### COMPLAINT
+
+- 1. Plaintiff, JANE DOE II, hereby sues JEFFREY EPSTEIN and IM and states:
+
+#### JURISDICTION AND VENUE
+
+- 2. This is an action for damages in excess of \$75,000, exclusive of interests, costs and attorney's fees.
+- 3. Venue is proper in this Court as all acts occurred in Palm Beach County and all parties reside and/or do business herein.
+
+#### PARTIES
+
+- 4. Ms. DOE II is a natural person residing in Palm Beach County, Florida. During the events giving rise to this claim, she was a minor but has now reached majority. She files this suit under a pseudonym to protect her privacy because the acts alleged occurred while she was a minor.
+
+SCANNED
+
+5. Defendant EPSTEIN is a natural person, who is an adult, and who resides and/or does business in Palm Beach County, Florida, and who committed the acts alleged within the jurisdiction of Palm Beach County, Florida, within the boundaries of the United States District Court in and for the Southern District of Florida. Defendant is a natural person, who is an adult, believed to reside in the State of New York, but who committed the acts alleged within the jurisdiction of Palm Beach County, Florida, within the boundaries of the United States District Court in and for the Southern District of Florida.
+
+6. Defendant EPSTEIN is believed to now be incarcerated in the Palm Beach County Jail for crimes committed that are related to and/or similar to the claims in this case.
+
+#### FACTS
+
+7. Defendant EPSTEIN was, at all times relevant to this action, a part time resident of Palm Beach County, Florida. All acts complained of herein occurred at his estate residence in the Town of Palm Beach, Florida.
+
+8. Defendant EPSTEIN has a history of enticing young women, who are minors (under 18 years of age), and soliciting them to engage in prostitution for his own sexual gratification.
+
+9. Defendant EPSTEIN, in agreement with two (2) persons he employed for this purpose, and Defendant , conspired with these other two, and others, to solicit young women of the type Defendant EPSTEIN preferred, blonde, attractive in appearance, and younger than 18 years of age, to provide sexual gratification for him by engaging in acts of prostitution.
+
+10. Defendants EPSTEIN and entered into a criminal conspiracy to solicit young women for acts of prostitution, including the Plaintiff, here in Palm Beach County.
+
+11. From about June, 2003 until on or about February, 2005, Defendants EPSTEIN ale persuaded, induced, or enticed the Plaintiff to come to Defendant EPSTEIN's home and provide Defendant EPSTEIN with "massages" which escalated into sexual encounters between Defendant EPSTEIN and the Plaintiff designed to fulfill his unnatural sexual desires for young women or even younger girls who were minors. These acts included Defendant EPSTEIN's request that he wanted the encounter to be like a "porn video." Defendant EPSTEIN would script lines for the Plaintiff to say, including calling out his name and requesting that he perform a certain sexual act "harder,"while he touched the Plaintiffs vagina with a vibrator or with his fingers; alternately, he would masturbate in the presence of the Plaintiff after demanding her to disrobe and walk in front of him in provocative sexual poses. Defendant EPSTEIN would pay the Plaintiff a fee of \$200 on each occasion after he ejaculated while masturbating in the presence of the Plaintiff.
+
+12. Defendant EPSTEIN touched Plaintiffs vagina, or penetrated Plaintiffs vagina, using his fingers and/or a vibrator on multiple occasions, during the time that Plaintiff was a minor, causing personal injury to her.
+
+13. In violation of 18 U.S.C. §2422(b),Defendants EPSTEIN and knowingly persuaded, induced, or enticed the Plaintiff to engage in acts of prostitution, when the Plaintiff was under the age of 18, approximately on or about the following dates that Plaintiff can document based on payments received: 6/16/03, 7/2/03, 4/9/04, 6/7/04, 7/30/04, 8/30/04, 10/9/04, 10/12/04, 10/30/04 and 11/9/04. In addition, Plaintiff believes that there were as many as 10 to 20 other occasions during this time frame that Defendant EPSTEIN solicited her and procured her to perform prostitution services, all during the time that she was a minor.
+
+14. Plaintiff seeks damages for personal injury in accordance with 18 U.S.C. §2255(a) for each of the acts of prostitution set forth above for which Defendants solicited her, \$150,000 for each violation, for a total range of damages between \$1.5 million dollars to \$4.5 million dollars, jointly and severally, and a reasonable attorney's fees and costs, as permitted by the statute.
+
+15. Defendant EPSTEIN has made an agreement with the United States Attorney's Office to not contest liability for claims brought exclusively pursuant to 18 U.S.C. §2255, in exchange for avoiding federal prosecution under 18 U.S.C. §2422(b), which provides a sentence of 10 years for each violation of the law.
+
+WHEREFORE, Plaintiff demands judgment in her favor, and a jury trial on all issues so triable as of right.
+
+Res tted,
+
+BY: ISI CIA Flo No. 437883 GA CIA LAW FIRM, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 Telephone:(561) 832-7732 Telecopier: (561) 832-7137 e-mail: isidrogarcia@bellsouth.net
+
+Date: 51 ICIP
+
+Mar. 24, 2009
+
+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 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 the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
+
+NOTICE: Attorneys MUST Indicate All Re-filed
+
+I. (a) PLAINTIFFS
+
+JANE DOE II
+
+DEFENDANTS
+
+JEFFREY EPSTEIN AND SARAH KELLEY
+
+STEVEN M. LARIMORE  
+CLERK U.S. DIST. CT.  
+S.D. OF FLA. - MIAMI
+
+(b) County of Residence of First Listed Plaintiff PALM BEACH  
+(EXCEPT IN U.S. PLAINTIFF CASES)
+
+County of Residence of First Listed Defendant PALM BEACH  
+(IN U.S. PLAINTIFF CASES ONLY)
+
+(c) Attorney's (Firm Name, Address, and Telephone Number)
+
+NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT LAND INVOLVED.
+
+LAW FIRM, P.A.  
+224 DATURA STREETM SUITE 900  
+WEST PALM BEACH, FL 33401
+
+Attorneys (If Known)  
+ROBERT D. CRITTON, ESQ.  
+JACK A. GOLDBERGER, ESQ.
+
+(d) Check County Where Action Arose:  MIAMI- DADE  MONROE  BROWARD  PALM BEACH  ST. LUCIE  INDIAN RIVER  OKEECHOBEE 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)  
+**09 CV 80469 KLR/AEV**
+
+III. CITIZENSHIP OF PRINCIPAL PARTIES
+
+(Place an "X" in One Box for Plaintiff and One Box for Defendant)  
+(For Diversity Cases Only)  
+PTF DEF  
+Citizen of This State  1  1 Incorporated or Principal Place of Business In This State  4  4  
+Citizen of Another State  2  2 Incorporated and Principal Place of Business In Another State  5  5  
+Citizen or Subject of a Foreign Country  3  3 Foreign Nation  6  6
+
+IV. NATURE OF SUIT
+
+| CONTRACT                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | TORTS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | FORFEITURE/PENALTY                                                                                                                                                                                                                                                                                                                                                                                                                           | BANKRUPTCY                                                                                                                                                                                                                                                                                                                                                                                                     | OTHER STATUTES                                                                                                                                                                                                                                                                                                                                                                                            |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
+|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| <input type="checkbox"/> 110 Insurance<br><input type="checkbox"/> 120 Marine<br><input type="checkbox"/> 130 Act<br><input type="checkbox"/> 140 Negotiable Instrument<br><input type="checkbox"/> 150 Recovery of Overpayment & Enforcement of Judgment<br><input type="checkbox"/> 151 Medicare Act<br><input type="checkbox"/> 152 Recovery of Defaulted Student Loans (Excl. Veterans)<br><input type="checkbox"/> 153 Recovery of Overpayment of Veteran's Benefits<br><input type="checkbox"/> 160 Stockholders' Suits<br><input type="checkbox"/> 190 Other Contract<br><input type="checkbox"/> 195 Contract Product Liability<br><input type="checkbox"/> 196 Franchise | <input type="checkbox"/> 310 Airplane<br><input type="checkbox"/> 315 Airplane Product<br><input type="checkbox"/> 320 Assault, Libel & Slander<br><input type="checkbox"/> 330 Federal Employers' Liability<br><input type="checkbox"/> 340 Marine<br><input type="checkbox"/> 345 Marine Product Liability<br><input type="checkbox"/> 350 Motor Vehicle<br><input type="checkbox"/> 355 Motor Vehicle Product Liability<br><input checked="" type="checkbox"/> 360 Other Personal Injury | <input type="checkbox"/> 362 Personal Injury - Med. Malpractice<br><input type="checkbox"/> 365 Personal Injury - Product Liability<br><input type="checkbox"/> 368 Asbestos Personal Injury Product Liability<br><input type="checkbox"/> 370 Other Fraud<br><input type="checkbox"/> 371 Truth in Leading<br><input type="checkbox"/> 380 Other Personal Property Damage<br><input type="checkbox"/> 385 Property Damage Product Liability | <input type="checkbox"/> 610 Agriculture<br><input type="checkbox"/> 620 Other Food & Drug<br><input type="checkbox"/> 625 Drug Related Seizure of Property 21 USC 881<br><input type="checkbox"/> 630 Liquor Laws<br><input type="checkbox"/> 640 R.R. & Truck<br><input type="checkbox"/> 650 Airline Regs.<br><input type="checkbox"/> 660 Occupational Safety/Health<br><input type="checkbox"/> 690 Other | <input type="checkbox"/> 422 Appeal 28 USC 158<br><input type="checkbox"/> 423 Withdrawal 28 USC 157<br><br><b>PROPERTY RIGHTS</b><br><input type="checkbox"/> 820 Copyrights<br><input type="checkbox"/> 830 Patent<br><input type="checkbox"/> 840 Trademark                                                                                                                                            | <input type="checkbox"/> 400 State Reapportionment<br><input type="checkbox"/> 410 Antitrust<br><input type="checkbox"/> 430 Banks and Banking<br><input type="checkbox"/> 450 Commerce<br><input type="checkbox"/> 460 Deportation<br><input type="checkbox"/> 470 Racketeer Influenced and Corrupt Organizations<br><input type="checkbox"/> 480 Consumer Credit<br><input type="checkbox"/> 490 Cable/Sat TV<br><input type="checkbox"/> 810 Selective Service<br><input type="checkbox"/> 850 Securities/Commodities/Exchange<br><input type="checkbox"/> 875 Customer Challenge<br><input type="checkbox"/> 12 USC 3410<br><input type="checkbox"/> 890 Other Statutory Actions<br><input type="checkbox"/> 891 Agricultural Acts<br><input type="checkbox"/> 892 Economic Stabilization Act<br><input type="checkbox"/> 893 Environmental Matters<br><input type="checkbox"/> 894 Energy Allocation Act<br><input type="checkbox"/> 895 Freedom of Information Act<br><input type="checkbox"/> 900 Appeal of Fee Determination Under Equal Access to Justice<br><input type="checkbox"/> 950 Constitutionality of State Statutes |
+| REAL PROPERTY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | CIVIL RIGHTS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | PRISONER PETITIONS                                                                                                                                                                                                                                                                                                                                                                                                                           | LABOR                                                                                                                                                                                                                                                                                                                                                                                                          | SOCIAL SECURITY                                                                                                                                                                                                                                                                                                                                                                                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
+| <input type="checkbox"/> 210 Land Condemnation<br><input type="checkbox"/> 220 Foreclosure<br><input type="checkbox"/> 230 Rent Lease & Ejectment<br><input type="checkbox"/> 240 Torts to Land<br><input type="checkbox"/> 245 Tort Product Liability<br><input type="checkbox"/> 290 All Other Real Property                                                                                                                                                                                                                                                                                                                                                                    | <input type="checkbox"/> 441 Voting<br><input type="checkbox"/> 442 Employment<br><input type="checkbox"/> 443 Housing/Accommodations<br><input type="checkbox"/> 444 Welfare<br><input type="checkbox"/> 445 Amer. w/Disabilities Employment<br><input type="checkbox"/> 446 Amer. w/Disabilities Other                                                                                                                                                                                    | <input type="checkbox"/> 510 Motions to Vacate Sentence<br><b>Habeas Corpus:</b><br>530 General<br><input type="checkbox"/> 535 Death Penalty<br><input type="checkbox"/> 540 Mandamus & Other                                                                                                                                                                                                                                               | <input type="checkbox"/> 710 Fair Labor Standards Act<br><input type="checkbox"/> 720 Labor/Mgmt. Relations<br><input type="checkbox"/> 730 Labor/Mgmt. Reporting & Disclosure Act<br><input type="checkbox"/> 740 Railway Labor Act<br><input type="checkbox"/> 790 Other Labor Litigation<br><input type="checkbox"/> 791 Empl. Ret. Inc. Security Act                                                       | <input type="checkbox"/> 861 HIA (1395ff)<br><input type="checkbox"/> 862 Black Lung (923)<br><input type="checkbox"/> 863 DIWC/DIWW (405(g))<br><input type="checkbox"/> 864 SSID Title XVI<br><input type="checkbox"/> 865 RSI (405(g))<br><br><b>FEDERAL TAX SUITS</b><br><input type="checkbox"/> 870 Taxes (U.S. Plaintiff or Defendant)<br><input type="checkbox"/> 871 IRS—Third Party 26 USC 7609 |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
+| JUDGE                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | IMMIGRATION                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                                                                                                                                                                                                                                                                                                                                                                                                |                                                                                                                                                                                                                                                                                                                                                                                                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
+|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | <input type="checkbox"/> 462 Naturalization Application<br><input type="checkbox"/> 463 Habeas Corpus-Alien Detaince<br><input type="checkbox"/> 465 Other Immigration Actions                                                                                                                                                                                                                                                                                                              |                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                                                                                                                                                                                                                                                                                                                                                                                                |                                                                                                                                                                                                                                                                                                                                                                                                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
+
+V. ORIGIN
+
+(Place an "X" in One Box Only)  
+ 1 Original Proceeding  2 Removed from State Court  3 Re-filed- (see VI below)  4 Reinstated or Reopened  5 Transferred from another district (specify)  6 Multidistrict Litigation  7 Appeal to District Judge from Magistrate Judgment
+
+VI. RELATED/RE-FILED CASE(S).
+
+(See instructions second page):
+
+a) Re-filed Case  YES  NO
+
+b) Related Cases  YES  NO
+
+DOCKET NUMBER **9:08-cv-80469-KAM**
+
+VII. CAUSE OF ACTION
+
+Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity):
+
+18 U.S.C. §2422(b)
+
+LENGTH OF TRIAL via \_\_\_\_\_ days estimated (for both sides to try entire case)
+
+VIII. REQUESTED IN COMPLAINT:
+
+ CHECK IF THIS IS A CLASS ACTION UNDER F.R.C.P. 23
+
+DEMAND S
+
+CHECK YES only if demanded in complaint:
+
+JURY DEMAND:  Yes  No
+
+ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE
+
+SIGNATURE OF ATTORNEY OF RECORD
+
+DATE  
+March 19, 2009
+
+FOR OFFICE USE ONLY  
+AMOUNT **350** RECEIPT # **725609**

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marker2/court-doe-v-epstein-80469/EFTA02750317/EFTA02750317.md

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+ft AO 440 /Rev 04/081 rIVIi summnm
+
+## UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of Florida
+
+JANE DOE II )
+
+Plaintiff )
+
+v. )
+
+JEFFREY EPSTEIN AND a. — )
+
+Defendant )
+
+Civil Action No. 09-CV-80469-RYSKAMP/VITUNAC
+
+#### Summons in a Civil Action
+
+To: (Defendant's name and address)
+
+3mipLNKJA SARAH BONK TREET, APARTMENT 14G-E NEW YORK, NY 10065
+
+A lawsuit has been filed against you.
+
+Within 20 days after service of this summons on you (not counting the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule I2 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attomey, whose name and address are:
+
+ESQ. 224 DA STREET, SUITE 900 WEST PALM BEACH, FL 33401
+
+If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
+
+Date: March 24, 2009
+
+![](_page_0_Picture_21.jpeg)
+
+Steven M. Larimore Clerk of Court
+
+SUMNIONS
+
+s/ R Blanchard Deputy Clerk U.S. District Courts
+
+<sup>(</sup>Use 60 days if the defendant is the United States or a United States agency, or is an officer or employee of the United States allowed 60 days by Rule 1201)(31)
+
+It AO 440 (Rev 04A131 runt Commons
+
+### UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of Florida
+
+JANE DOE II )
+
+Plaintiff )
+
+v. ) JEFFREY EPSTEIN AND ) Defendant )
+
+Civil Action No. 09-CV-80469-RYSKAMP/VITUNAC
+
+#### Summons in a Civil Action
+
+To: (Defendant's name and address)
+
+JEFFREY EPSTEIN, JACKET NO. 0338617 CIO PALM BEACH COUNTY STOCKADE 673 FAIRGROUNDS ROAD WEST PALM BEACH, FL 33411
+
+A lawsuit has been filed against you.
+
+Within 20 days after service of this summons on you (not counting the day you received it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff's attorney, whose name and address are:
+
+, ESQ. LAW FIRM, P.A.. 224 DATURA STREET, SUITE 900 WEST PALM BEACH, FL 33401
+
+If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
+
+Date: March 24, 2009
+
+![](_page_1_Picture_20.jpeg)
+
+Steven M. Larimore Clerk of Court
+
+# SUMMONS
+
+sf R Blanchard Deputy Clerk U.S. District Courts
+
+(Use 60 days if the defendant is the United States or a United States agency, or is an officer or emplace of the United States allowed 60 days by Rule 12(a)(3).)

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marker2/court-doe-v-epstein-80469/EFTA02750319/EFTA02750319.md

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case #09-80469-CIV-RYSKAMPWITUNAC
+
+Jane Doe II
+
+Plaintiff
+
+vs.
+
+Jeffrey Epstein &
+
+Defendant
+
+## ORDER OF PRETRIAL PROCEDURES
+
+This Order has been entered upon the filing of the Complaint. Plaintiffs counsel is hereby ORDERED to forward to all defendants, upon receipt of a responsive pleading, a copy of this Order. The Court directs the parties to review and comply with all Federal Rules of Civil Procedure governing pretrial procedures, and with all relevant general rules promulgated in the Southern District of Florida, including S.D. Fla. LR 26.1 and 16.1. The parties shall hold a scheduling meeting within twenty (20) days after the filing of the first responsive pleading by the last responding defendant, or within ninety (90) days after the filing of a complaint, whichever shall first occur, and prepare a scheduling report (that complies with Rule I6.1(BX2)) and a joint proposed Scheduling Order (sample attached), which shall be submitted to the court. A copy of the joint proposed Scheduling Order shall also be submitted in Word or WordPerfect format to Ryskamp@flsd.uscourts.gov (see the Court's intemet site, CM/ECF Administrative Procedures). At the aforementioned scheduling meeting the parties shall fulfill all the purposes and requirements of the discovery planning meeting required by Fed. R. Civ. P. 26(f), as amended.
+
+## FAILURE OF COUNSEL TO FILE A SCHEDULING REPORT WILL RESULT IN DISMISSAL, DEFAULT AND THE IMPOSITION OF OTHER SANCTIONS INCLUDING ATTORNEYS FEES, COSTS AND EXPENSES. See S.D. Ha, LR 16.1(M)
+
+DONE AND ORDERED in at West Palm Beach, Florida, this 25th day of March, 2009.
+
+/S/ Kenneth L. Rvslcamp
+
+KENNETH L. RYSKAMP
+
+UNITED STATES DISTRICT JUDGE
+
+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case #09-80469-CIV-RYSKAMP
+
+Jane Doe II
+
+Plaintiff
+
+vs.
+
+Jeffrey Epstein &
+
+Defendant
+
+# SAMPLE SCHEDULING ORDER
+
+Pursuant to Local Rule 16.1(bX7), IT IS ORDERED AND ADJUDGED as follows:
+
+I. No pretrial conference shall be held in this action, unless the parties so request or the Court determines, sua sponte, that a pretrial conference is necessary. Should a pretrial conference be set, the compliance deadlines as set forth in the remainder of this Order shall remain unaltered.
+
+2. Counsel shall meet at least ONE MONTH prior to the beginning of the trial calendar to confer on the preparation of a pretrial stipulation.
+
+3. The joint pretrial stipulation shall be filed on or before the date set forth in the attached Notice of Trial and shall conform to Local Rule 16.1(e). The Court will not allow unilateral pretrial stipulations.
+
+4. In cases tried before a jury, each party shall file the proposed jury instructions at least ONE WEEK prior to the beginning of the trial calendar. Additionally, one copy of the proposed jury instructions shall be sent in Word or WordPerfect format to Rvskamp(4flsd.uscourts.gov. Each jury instruction shall be typed on a separate sheet and must be supported by citation of authority. In preparing their requested jury instructions, the parties shall utilize as a guide the Pattern July Instructions for civil cases approved by the United States Eleventh Circuit, including the Directions to Counsel contained therein. At the close of the evidence, a party may file additional instructions covering matters occurring at the trial that could not reasonably be anticipated, and with the Court's permission, file untimely requests for instructions on any issue.
+
+5. In cases tried before the Court, each party shall file the proposed findings of fact and conclusions of law at least ONE WEEK prior to the beginning of the trial calendar. Proposed conclusions of law shall be supported by citations of authority.
+
+6. All exhibits must be pre-marked. The plaintiff and defendant shall both mark their exhibits numerically. A typewritten exhibit list setting forth the number, and description of each exhibit shall be submitted at the time of trial. The parties shall submit said exhibit list on Form AO 187, which is available from the Clerk's office. All electronically filed exhibits should be listed as one attachment unless over 5mb (100 pages).
+
+7. A motion for continuance shall not stay the requirement for the filing of a pretrial stipulation and, unless an emergency situation arises, a motion for continuance will not be considered unless it is filed at least twenty (20) days prior to the date on which the trial calendar is scheduled to commence.
+
+8. Non-compliance with any provision of this order may subject the offending party to sanctions or dismissal. It is the duty of all counsel to enforce the timetable set forth herein in order to insure an expeditious resolution of this cause.
+
+9. The following timetable shall govern the pretrial procedure in this case. This schedule shall not be modified absent compelling circumstances.
+
+Joinder of additional parties and amended pleadings
+
+\* Plaintiff shall furnish opposing counsel with a written list containing the names and addresses of all expert witnesses intended to be called at trial and only those expert witnesses listed shall be permitted to testify. Within the 14 day period following this disclosure, the plaintiff shall make its experts available for deposition by the defendant. The experts' depositions may be conducted without further order from the Court.
+
+\* Defendant shall furnish opposing counsel with a written list containing the names and addresses of all expert witnesses intended to be called at trial and only those expert witnesses listed shall be permitted to testify. Within the 14 day period following this disclosure, the defendant shall make its experts available for deposition by the plaintiff. The experts' depositions may be conducted without further order from the Court.
+
+Parties shall furnish opposing counsel with a written list containing the names and addresses of all witnesses intended to be called at trial and only those witnesses listed shall be permitted to testify.
+
+All discovery must be completed.
+
+All pretrial motions and memoranda of law must be filed. (No later than one month after the close of discovery)
+
+■(insert **a specific date -- e.g. "October I, 2009" -- not "30 days prior to etc.")** 
+
+Pretrial Stipulation required by Local Rule 16.1.E shall be filed by
+
+This case is assigned to the track.
+
+This is a trial. (Jury or Non-Jury)
+
+10. Trial date and calendar call will be set by separate notice.
+
+II. If this case is settled, counsel are directed to inform the Court promptly by calling and submitting an appropriate order for dismissal, within ten (10) days of notification of settlement to the Court, pursuant to Fed. R. Civ. P. 41(aX1).
+
+Dated this day of , 2009.
+
+KENNETH L. RYSKAMP United States District Judge
+
+copies provided:

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marker2/court-doe-v-epstein-80469/EFTA02750323/EFTA02750323.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 09-80469-CIV-RYSICAMPNITUNAC
+
+JANE DOE II,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN and
+
+Defendants.
+
+## ORDER OF TRANSFER
+
+GOOD CAUSE appearing that a transfer of this case is appropriate pursuant to Local Rule 3.9(c) due to lower-numbered Case Nos. 08-80069, 08-80119; 08-80232; 08-80380; 08- 80381; 08-80804; 08-80811; 08-80893; 08-80993; and 08-80994-C1V-MARRA and subject to the consent of the Honorable Kenneth A. Marra, it is hereby,
+
+ORDERED AND ADJUDGED that the above-styled matter is transferred to the calendar of Judge Marra for all further proceedings.
+
+DONE AND ORDERED in March, 2009. at West Palm Beach, Florida, this 24 day of
+
+> iNNETII L. RYS ITED STATES DISTRICT JUDGE
+
+After reviewing the Court file in the above numbered Causes, 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, 09-80469-CIV-MARRA, thereby indicating the Judge to whom all pleadings should be routed or otherwise brought for attention.
+
+-it THE FOREGOING transfer is herewith accepted this OS day of March, 2009.
+
+> HON. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE
+
+Copies provided to: Honorable Kenneth L. Ryskamp Honorable Kenneth A. Marra All counsel of record

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marker2/court-doe-v-epstein-80469/EFTA02750325/EFTA02750325.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 09-80469-CIV-MARRA
+
+JANE DOE II,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN and SARA
+
+Defendants.
+
+## ORDER REQUIRING COUNSEL TO CONFER, FILE JOINT SCHEDULING REPORT AND FILE JOINT DISCOVERY REPORT
+
+THIS ORDER has been entered upon the filing of the complaint. Plaintiff's counsel is hereby ORDERED to forward to all defendants, upon receipt of either an answer or a motion pursuant to Fed. R. Civ. P. 12(b), a copy of this order.
+
+It is further ORDERED:
+
+- I. Every motion when filed shall be accompanied by a proposed order, except that motions to dismiss and motions for summary judgment need not be accompanied by a proposed order.
+- 2. Pretrial discovery in this case shall be conducted in accord with Local Rule 16.1 and Rule 26 of the Federal Rules of Civil Procedure.
+- 3. Pursuant to Rule 26(f) of the Federal Rules of Civil Procedure, unless this action is excluded under Rule 26(a)(I)(E), the parties must confer within twenty-one (21) days after the last responding party either files an answer or a motion pursuant to Fed. IL Civ. P. 12(b), whichever is earlier, to consider the nature and basis of their claims and defenses and the possibilities for a prompt settlement or resolution of the case, to make or arrange for the disclosures required by Rule 26(a)(1), and to develop a proposed discovery plan that indicates the
+
+parties' views and proposals concerning the matters listed in Rule 26(t).
+
+4. The parties are jointly responsible for submitting a written report of this conference outlining the proposed discovery plan within 14 days after the conference.
+
+5. Counsel for the parties shall hold a scheduling conference either at the same time as the discovery conference described in Rule 26(t) or within fourteen (14) calendar days thereafter. See Local Rule 16.1(B).
+
+6. Within fourteen (14) days of the scheduling conference, counsel shall file a joint scheduling report pursuant to Local Rule 16.1(B)(2). This report shall indicate the proposed month and year for the trial plus the estimated number of trial days required, as well as an indication of whether the trial is to be a jury trial or bench trial.
+
+7. The parties may submit a single report combining the discovery plan report and the scheduling conference report.
+
+8. Failure of counsel or unrepresented parties to file a discovery plan report or joint scheduling report may result in dismissal, default, and the imposition of other sanctions including attorney's fees and costs.
+
+DONE AND SIGNED in at West Palm Beach, Palm Beach County, Florida, this 30th day of March, 2009.
+
+KENNETH A. MARRA United States District Judge
+
+Copies furnished to:
+
+All counsel

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marker2/court-doe-v-epstein-80469/EFTA02750327/EFTA02750327.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,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 4,
+
+Plaintiff,
+
+vs. JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+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-MARRAi
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+JANE DOE NO. 101, CASE NO.: 09- 80591-CIV-MARRa
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## ORDER
+
+THIS CAUSE is before the Court on Plaintiff? Motion for Protective Order Against Piecemeal Depositions of Jane Doe No.'s 2, 3, 4, and 7 and Motion to Consolidate Cases for Purposes of Discovery (DE 66 in 08-80119; DE 58 in 08-80232; DE 73 in 08-80380; DE 23 in 08-80993). The Court has reviewed the motions, responses, replies, and is otherwise fully advised in the premesis. It is hereby
+
+ORDERED AND ADJUDGED as follows:
+
+Plaintiffs' Motion for Protective Order Against Piecemeal Depositions is GRANTED, pursuant to Fed. R. Civ. P. 26(c). As to each of the ten above-styled cases, Defendant is limited to a single deposition of each Plaintiff, during which Defendant may depose the plaintiff as both a party and a witness to all other cases of a similar nature of which the plaintiff deposed is aware. Defendant should not expect to be able to re-depose any plaintiff relative to any new cases that may be filed. Therefore, Defendant should examine each plaintiff about the facts relating to all individuals of whom they are aware, regardless of whether an individual has in fact filed a claim against Defendant. In the event additional cases are filed, upon a showing of good cause, the Court will determine whether Defendant will be permitted to re-depose any of the plaintiffs as witnesses to the allegations made in those newly filed cases.
+
+Plaintiffs' Motion to Consolidate Cases for Purposes of Discovery is GRANTED. In the interests of judicial economy and efficiency, cases 08-80119, 08-80232, 08-80380, and 08-80993 are hereby CONSOLIDATED for purposes of discovery only.
+
+Additionally, the parties in the other six above-styled causes (08-80381, 08-80994, 08-80811, 08-80893 09-80469, 09-80591) are hereby ORDERED TO SHOW CAUSE on or before May 5, 2009 why all of the cases should not be consolidated for discovery purposes.
+
+DONE AND ORDERED in Florida, this 28th day of April, 2009 at West Palm Beach, Palm Beach County,
+
+Copies furnished to: all counsel of record
+
+rZ KENNETH A. MARRA United States District Judge

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marker2/court-doe-v-epstein-80469/EFTA02750331/EFTA02750331.md

@@ -0,0 +1,77 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 09-CIV- 80469 — MARRa
+
+JANE DOE II,
+
+Plaintiff, v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## DEFENDANT'S UNOPPOSED MOTION FOR EXTENSION TO FILE A RESPONSE TO COMPLAINT
+
+Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned attorneys, respectfully moves this Court for an extension of time in which to file his Response to Plaintiffs Complaint.
+
+- 1. On March 25, 2009 Plaintiff filed a Complaint [DE 1] in the within matter. Plaintiff and Defendant counsel agreed Defendant would file a response by May 1, 2008. Defendant is requesting a five day extension to May 6, 2009 to respond.
+- 2. There are several other cases filed with this Court in which Jeffrey Epstein is named a Defendant. In those cases, the undersigned has been handling other matters associated therewith.
+- 3. Additionally, Defendant's counsel is in the midst of preparing for a state court trial, CARDIOPULMONARY & PRIMARY CARE ASSOC. OF TREASURE COAST, P.A
+- v. , M.D., Case No. 562008CA001726, specially set for trial beginning May 13
+
+Jane Doe II v. Epstein, et al. Page 2
+
+through 15, 2009). Discovery in that case is ongoing with several depositions set to prepare for trial.
+
+4. An extension until May 6, 2009, is fair and reasonable under the circumstances. The undersigned is in need of the additional time in order to fully and adequately prepare a response on behalf of EPSTEIN.
+
+5. As certified below, counsel for Defendant conferred with Plaintiffs counsel counsel by telephone, and Plaintiff's counsel is in agreement with the requested extension.
+
+WHEREFORE Defendant respectfully requests that this Court enter an order granting an extension until May 6, 2009, to file a Response to Plaintiffs Complaint.
+
+## Local Rule 7.1 Statement
+
+Counsel for the movant conferred by telephone with counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested extension until May 6, 2009 for Defendant to file a Response to Plaintiff's Complaint. 1
+
+Robert D. C itton, Jr. Attorney for Defendant Epstein
+
+## 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 via transmission of Notices of Electronic Filing generated by CM/ECF on this 1st day of Mav , 2009:
+
+=, Esq. Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400
+
+Jane Doe II v. Epstein, et al.  
+Page 3
+
+561-832-7732  
+561-832-7137 F  
+[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net)  
+*Counsel for Plaintiff*
+
+West Palm Beach, FL 33401-5012  
+561-659-8300  
+561-835-8691 Fax  
+[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net)  
+*Co-Counsel for Defendant Jeffrey Epstein*
+
+![]()![]()ROBERT D. CRITTON, JR., ESQ.  
+Florida Bar No. 224162
+
+[rcrit@bclclaw.com](mailto:rcrit@bclclaw.com)
+
+MICHAEL J. PIKE, ESQ.  
+Florida Bar #617296
+
+[mpike@bclclaw.com](mailto:mpike@bclclaw.com)
+
+BURMAN, CRITTON, LUTTIER & COLEMAN  
+515 N. Flagler Drive, Suite 400
+
+West Palm Beach, FL 33401
+
+561-842-2820
+
+Fax: 561-515-3148
+
+*(Co-counsel for Defendant Jeffrey Epstein)*

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marker2/court-doe-v-epstein-80469/EFTA02750334/EFTA02750334.md

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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 09-CIV- 80469 — MARRA/
+
+JANE DOE II,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+#### DEFENDANT EPSTEIN'S RESPONSE IN OPPOSITION TO THIS COURTS ORDER TO SHOW CAUSE AS WHY ALL CASES SHOULD NOT BE CONSOLIDATED FOR DISCOVERY PURPOSES AND MOTION TO CLARIFY THE COURT'S ORDER DATED APRIL 28, 2009
+
+Defendant, JEFFERY EPSTEIN, (EPSTEIN), by and through his undersigned attorneys, hereby files his Response in Opposition to this Court's Order to Show Cause as to Why All Cases Should Not be Consolidated for Purposes of Discovery and Motion for Clarification of this Courts Order on general consolidation of discovery (DE 6), and states:
+
+### I. Response In Opposition
+
+Defendant has no further objections to consolidating these cases for purposes of depositions as outlined in this Court's April 28, 2009 Order.
+
+However, to consolidate the cases for purposes of all "discovery" including, but not limited to, motion practice and related orders thereto will, without question, confuse many of the individual discovery issues raised not only by Epstein as to the individual Plaintiffs that have brought separate lawsuits against him, but will also confuse the individual discovery issues raised by those same individual Plaintiffs as to Epstein. This
+
+will undoubtedly lead to several motions to clarify certain orders which will seek explanation from the court as to how those orders affect Epstein as to each individual Plaintiff's discovery requests and vice versa (i.e., how those future orders affect the individual Plaintiffs' discovery requests directed to Epstein).
+
+It is important to note that each related Federal matter before this court has its very own distinct set of facts and defenses thereto. As such, the discovery served and the responses received are particular and individualized as to both Plaintiff and Defendant. As such, discovery of "tall" cases for general discovery consolidation (separate and apart from depositions) will only cloud rulings on discovery and will result in more attorney labor and judicial resources, which will inevitably be spent on motions for clarification.
+
+Each Plaintiff and Epstein have served and will in the future serve separate requests for production, separate interrogatories, separate requests for admissions, and separate motions to compel, responses and replies addressing certain discovery issues. Obviously, both Plaintiff and Defendant will base their discovery related arguments on the particularized facts of each case, which are separate and distinct from one another. Moreover, the Plaintiffs will likely seek to retain different experts to support their individual claims. In that regard, how will a general consolidation of discovery impact discovery related to those experts' individualized opinions?
+
+As this court is aware, certain case management orders are in place setting the parameters of discovery. It is unclear how Plaintiffs' Motion to Consolidate and the Courts Order will handle the potential problems and any other potential discovery related issues outlined above. In fact, it appears that Jane Doe, in Case No. 08-CV-
+
+80893 (DE 47), has expressed her own reasons for opposing the consolidation all the cases for discovery purposes. Obviously, Jane Doe's counsel, like the undersigned, anticipates that discovery issues will present themselves if general consolidation occurs and does not want it to impact her case. In fact, the debates have already begun in light of this Court's April 29, 2009 Order and the responses filed addressing same. This provides the court with a glimpse of what will occur if general consolidation occurs, in particular, how attorney resources and judicial resources will be unnecessarily used.
+
+In addition, the initial style of each case should be maintained in pleadings and in orders in an effort to maintain organization and application of the rulings this court espouses for each case. Utilizing a compound multiple-type style will only confuse cases that should be kept separate for all discovery purposes.
+
+# II. Motion for Clarification of this Court's April 28, 2009 Order
+
+This Court ruled that cases 08-80119, 08-80232, 08-80380 and 08-80993 are consolidated for discovery purposes. Epstein not only objects to the court's consolidation order but seeks clarification from this Court as to how consolidation of general discovery will impact motion practice and orders in the above cases. What does the court mean when it says the above cases are consolidated "for purposes of discovery only?" How does consolidation operate? The concerns addressing general discovery consolidation are set out above and are therefore incorporated herein. Likewise, for those reasons, the court should reverse its ruling on consolidation and issue a new order maintaining the individuality of each case for discovery purposes.
+
+In addition, Epstein not only objects to the court's potential consolidation of case numbers 08-80381, 08-80994, 08-80811, 08-80893, 09-80469 and 09-80591 for
+
+general discovery purposes, but respectfully requests that this court clarify how consolidation of general discovery will impact motion practice and orders in the above cases should this court choose to consolidate same for discovery. Again, how does consolidation operate? The concerns addressing general discovery consolidation are set out above and are therefore incorporated herein.
+
+In short, the Motions seeking consolidation for discovery purposes only do not delineate how consolidation operates. As such, the Order granting the Motions to Consolidate for discovery purposes only does not provide any additional information addressing how consolidation will operate.
+
+WHEREFORE, Defendant requests that this Court not consolidate case numbers 08-80381, 08-80994, 08-80811, 08-80893, 09-80469 and 09-80591, that it clarify its order as to consolidation of case numbers 08-80119, 08-80232, 08-80380 and 08- 80993 (or the future consolidation of other cases) and that it reverse its April 28, 2009 ruling on general consolidation in light of the potential problems presented in this response, that an order be entered requiring the parties to utilize the style secured by the initial case filing and not a compound-case style incorporating all case styles in one particular document, and for such other and further relief as is Court deems just and proper.
+
+B
+
+MICHAEL J. PIKE, ESQ. Florida Bar #617296
+
+## 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 via transmission of Notices of Electronic Filing generated by CM/ECF on this 4 day of Aug, 2009:
+
+Isidro M. [REDACTED], Esq.  
+[REDACTED] Law Firm, P.A.  
+224 Datura Street, Suite 900  
+West Palm Beach, FL 33401  
+561-832-7732  
+561-832-7137 F  
+[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net)  
+*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  
+561-835-8691 Fax  
+[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net)  
+*Co-Counsel for Defendant Jeffrey Epstein*
+
+Respectfully submitted,
+
+![]()*(Co-counsel for Defendant Jeffrey Epstein)*

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marker2/court-doe-v-epstein-80469/EFTA02750339/EFTA02750339.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 09-CIV- 80469 — MARRS
+
+JANE DOE II,
+
+Plaintiff, v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## DEFENDANT EPSTEIN'S UNOPPOSED MOTION TO EXCEED PAGE LIMITATION FOR DEFENDANTS MOTION TO DISMISS & SUPPORTING MEMORANDUM OF LAW DIRECTED TO PLAINTIFF'S COMPLAINT
+
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, moves to exceed the page limitation of 20 pages imposed by Loc. Gen. Rule 7.1. C. 2. (S.D. Fla.), in his memorandum of law in support of his motion to dismiss directed to Plaintiff JANE DOE II's Complaint [DE 1], filed March 25, 2009. In support of his motion, Defendant states:
+
+1. Local Gen. Rule 7.1 C. 2. provides in part that absent prior permission of the court, no party shall file any legal memorandum exceeding 20 pages in length. Defendant is in the process of preparing his motion to dismiss and supporting memorandum of law directed to Plaintiffs Complaint, (which is due by an extension to May 6, 2009), and the legal memorandum will exceed the 20 page limitation. It is clear based on the issues raised in Plaintiff's Complaint that in excess of 20 pages is required to fully and adequately discuss the issues raised in moving to dismiss Plaintiffs action.
+
+2. The issues being addressed include but are not limited to constitutional law issues and what version of 18 U.S.C.A. §2255 applies to this action, and the meaning of §2255 with respect to the cause of action created and the presumptive minimum Jane Doe II v. Epstein. et al. Page 2
+
+damages amount imposed. (It is Defendant's position that the 2006 amended version does NOT apply to this action; rather, it is the statute in effect during the time of the alleged conduct that apply).
+
+3. Plaintiffs Complaint seeks to multiple the presumptive minimum damages amount under 18 U.S.C. §2255 and references the 2006 amended version of the statute, which most significantly increased triple-fold the presumptive minimum damages amount imposed from \$50,000 to \$150,000.
+
+4. A length exceeding 20 pages is required so that Defendant may fully address the issues raised in Plaintiffs Complaint and in seeking dismissal thereof. Under the constitutional guarantees of due process, including a fair and full opportunity to be heard, and in the interests of justice so that the Court may render a fully informed decision on the issue, Defendant is entitled to an order granting his motion to exceed the page limitation. (Excluding endnotes, quoting statutory text and Complaint allegations, it appears that Defendant's legal memorandum will be approximately 24 to 28 pages.)
+
+5. As certified below herein, Plaintiffs counsel agreed to the request to exceed 20 pages.
+
+WHEREFORE, Defendant respectfully requests that this Court grant Defendant's motion, and enter an order allowing Defendant's legal memorandum in support of dismissal of Plaintiff's action to be in excess of 20 pages.
+
+Jane Doe II v. Epstein, et al.  
+Page 3
+
+**Rule 7.1 Certification**
+
+Pursuant to communication by telephone, Plaintiff's counsel has no objection to the request to exceed 20 pages herein.
+
+![]()**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 via transmission of Notices of Electronic Filing generated by CM/ECF on this 5-8 day of May, 2009:
+
+Isidro M. [REDACTED] Esq.  
+[REDACTED] Law Firm, P.A.  
+224 Datura Street, Suite 900  
+West Palm Beach, FL 33401  
+561-832-7732  
+561-832-7137 F  
+[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net)  
+*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  
+561-835-8691 Fax  
+[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net)  
+*Co-Counsel for Defendant Jeffrey Epstein*
+
+Respectfully submitted,
+
+![]()*(Co-counsel for Defendant Jeffrey Epstein)*

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marker2/court-doe-v-epstein-80469/EFTA02750342/EFTA02750342.md

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+#### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+JANE DOE II ) CASE NO.:50 2008CA020614)OOO(MBAF
+
+)
+
+Plaintiff, )
+
+)
+
+vs. )
+
+)
+
+JEFFREY EPSTEIN, ) cat,.
+
+and )
+
+)
+
+Defendants. )
+
+## FIRST AMENDED COMPLAINT'
+
+I . Plaintiff, JANE DOE II, hereby sues JEFFREY EPSTEIN and , and states:
+
+### JURISDICTION AND VENUE
+
+- 2. This is an action for damages in excess of \$15,000, exclusive of interests and costs.
+- 3. Venue is proper in this Court as all acts occurred in Palm Beach County and all parties reside and/or do business herein.
+
+### PARTIES
+
+- 4. Ms. DOE II is a natural person residing in Palm Beach County, Florida. During the events giving rise to this claim, she was a minor but has now reached majority.
+  - 5. Defendant EPSTEIN is a natural person who resides and/or does business in Palm
+
+EXHIBIT "A`f
+
+Amended to correct scrivener's error on 111 of the Complaint relating to the dates of the occurrences.
+
+Beach County, Florida, and who committed the acts alleged within the jurisdiction of Palm Beach County, Florida. Defendant is believed to reside in the State of New York, but committed the acts alleged within the jurisdiction of Palm Beach County, Florida.
+
+6. Defendant EPSTEIN is believed to now be incarcerated in the Palm Beach County Jail for crimes committed that are related andlor similar to the claims in this case.
+
+#### FACTS
+
+7. Defendant EPSTEIN was, at all times relevant to this action, a part time resident of Palm Beach, Florida. All acts complained of herein occurred at his estate residence in Palm Beach, Florida.
+
+8. Defendant EPSTEIN has a history of enticing young women, under the age of consent, to private sessions that begin with massages and evolve, through his acts of solicitation by use of his lavish wealth, into sexual encounters, wherein Defendant EPSTEIN fulfills sexual fantasies by using said young women.
+
+9. Defendant EPSTEIN, in agreement with two (2) persons he employed for this purpose, and Defendant a, conspired with these other two Defendants to solicit young women of the type Defendant EPSTEIN preferred, blonde, attractive in appearance, and younger than the age of legal consent, to provide sexual gratification for him.
+
+10. Defendants EPSTEIN and entered into a criminal conspiracy to solicit young women for acts of prostitution, including the Plaintiff.
+
+II. From about June or July, 2004 until on or about February, 2005, Defendants EPSTEIN and solicited the Plaintiff to come to Defendant EP STEIN's home and provide "massages" for him. Defendant EPSTEIN corrupted young girls, such as Plaintiff, into engaging in sexual acts
+
+to designed to fulfill his unnatural sexual desires for young women or even younger girls who were under the age of consent. These acts included his requests that he wanted the encounter to be like a "porn video." Defendant EPSTEIN would script lines for Plaintiff- to say, including calling out his name and requesting that he perform a certain sexual act "harder,"while he touched the Plaintiff's vagina with a vibrator or with his fingers; alternately, he would masturbate in the presence of the Plaintiff after demanding her to disrobe and walk in front of him in provocative sexual poses.
+
+12. Defendant EPSTEIN touched Plaintiff's vagina, or penetrated Plaintiff's vagina, using his fingers and/or a vibrator on multiple occasions, during the time that Plaintiff was a minor.
+
+# COUNT I: SEXUAL BATTERY
+
+13. Plaintiff reasserts and alleges, as if fully set forth in Count I, the allegations ofd 1-12, supra.
+
+14. Defendant EPSTEIN unlawfully touched the Plaintiff without Plaintiff's consent, and before she reached the age of consent, with the intention of bringing about a harmful and offensive contact.
+
+15. As a direct and proximate result of said unlawful touching, plaintiff suffered physical injuries, severe emotional distress, mental anguish and distress, humiliation and embarrassment and continues to suffer so today.
+
+WHEREFORE, Plaintiff respectfully requests that this Court:
+
+A. Award Plaintiff compensatory damages for humiliation, loss of reputation, mental anguish and pain and suffering; and
+
+B. Award Plaintiff her costs of this action.
+
+# COUNT II: CIVIL CONSPIRACY
+
+16. Plaintiff reasserts and alleges, as if fully set forth in Count I, the allegations of 111-12, supra.
+
+17. Defendants entered into a criminal conspiracy to solicit young women for the sexual gratification of Defendant EPSTEIN, including, but not limited to, soliciting the Plaintiff and others like her for him to exploit and take advantage of their youth, inexperience and financial need.
+
+18. As a direct and proximate result of said unlawful touching, plaintiff suffered physical • injuries, severe emotional distress, mental anguish and distress, humiliation and embarrassment and continues to suffer so today.
+
+WHEREFORE, Plaintiff respectfully requests that this Court:
+
+- A. Award Plaintiff compensatory damages for humiliation, loss of reputation, mental anguish and pain and suffering; and
+- B. Award Plaintiff her costs of this action.
+
+#### JURY DEMAND
+
+## PLAINTIFF DEMANDS A JURY TRIAL ON ALL ISSUES SO TRIABLE.
+
+Respectfu / yo ubmined
+
+ISII O M. r RCIA 1F. 37 No.: 437883 ELKINS & BOEHRINGER, P.A. 224 Datura St., Ste. 900 West Palm Beach, FL 33401 Telephone: (561) 832-8033 Telecopier: (561) 832-7137 E-mail: isidrostarcia®bellsouth.net COUNSEL FOR PLAINTIFF
+
+Dated: t t, 3-c 9'

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marker2/court-doe-v-epstein-80469/EFTA02750346/EFTA02750346.md

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+27
+
+THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT  
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CASE ID: 502008CA020614XXXXMB  
+DIVISION: AB
+
+JANE DOE II
+
+vs
+
+JEFFREY EPSTEIN
+
+CLERK'S NOTICE OF REASSIGNMENT
+
+Pursuant to Court Order of the Honorable JUDGE DIANA [REDACTED] dated APRIL 2, 2009, the above styled case is reassigned to Division AB, JUDGE DONALD W HAFELE for all further proceedings.
+
+WITNESS my hand and seal on APRIL 10, 2009.
+
+APR 10 AM 9:39  
+FLORIDA CIRCUIT COUNTY, FL  
+CIRCUIT COURT
+
+Sharon R. Bock  
+Clerk & Comptroller
+
+![](_page_0_Picture_190.jpeg)
+
+By: Midia Trauger  
+Deputy Clerk
+
+Robert Critton Jr, Esquire  
+Michael Pike, Esquire  
+Isidro [REDACTED], Esquire  
+Jack Goldberger, Esquire
+
+EXHIBIT "B"

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marker2/court-doe-v-epstein-80469/EFTA02750347/EFTA02750347.md

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 09-CIV- 80469 —
+
+JANE DOE II,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+### DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT, AND SUPPORTING MEMORANDUM OF LAW
+
+Defendant, Jeffrey Epstein, (hereinafter "Epstein"), by and through his undersigned attorneys, moves to dismiss Plaintiffs Complaint for failure to state a cause of action, and for more definite statement. Rule 12(b)(6), (e), Fed.R.Civ.P. (2008); Local Gen. Rule 7.1 (S.D. Fla. 2008). In support of dismissal, Defendant states:
+
+At the outset, Defendant gives notice to the Court that issues pertaining to 18 U.S.C. §2255 in this motion to dismiss are also raised in the case of C.M.A. v. Jeffrey Epstein Case No. 08-CV-80811-MARRAMM, in Defendant's Motion to Dismiss directed to Plaintiff C.M.A.'s Amended Complaint, Plaintiff C.M.A.'s Response, and Defendant's reply to C.M.A.'s response (which has yet to be filed).
+
+In this action, Plaintiffs Complaint attempts to allege a cause of action pursuant to 18 U.S.C. §2255 - Civil Remedies for Personal Injuries. Significantly, Plaintiff previously a filed lawsuit on July 10, 2008, based on the same facts as alleged herein in the Fifteenth Judicial Circuit In and For Palm Beach County, State of Florida, Case No.
+
+<sup>50</sup>2008CA020614 MBAF, Jane Doe II v. Jeffrey Epstein, and , (hereinafter "state action"). In attempting to allege aclaim under 18 U.S.C. §2255, Plaintiff improperly relies on the §2255, as amended, effective July 27, 2006. As discussed more fully below herein, the statute in effect during the time of the alleged conduct applies.
+
+Dismissal is required on several grounds: (1) Plaintiff previously filed a state action approximately 10 months ago against the same defendant involving the same alleged facts; (2) Plaintiff improperly relies on 18 U.S.C. §2255, as amended, effective July 27, 2006, rather than the version of the statute in effect during the time of the alleged conduct; (3) Plaintiff improperly asserts that the presumptive damages minimum under §2255 is subject to multiplication on a per violation basis; (4) Plaintiff has failed to allege <sup>a</sup>cause of action under 18 U.S.C. §2255 as she has failed to sufficiently allege facts constituting a predicate act; (5) Plaintiff has failed to state a cause of action of conspiracy to violate §2255.
+
+## Supporting Memorandum of Law
+
+I. Court is required to dismiss Plaintiff's action as there is already pending <sup>a</sup>previously filed state action arising from the same factual allegations.
+
+Exceptional circumstances merit the dismissal of this action as Plaintiff first filed <sup>a</sup>lawsuit on July 10, 2008, in the in the Fifteenth Judicial Circuit In and For Palm Beach County, State of Florida, Case No. 50 2008CA020614 MBAF, Jane Doe II v. Jeffrey Epstein, and l, based on the same factual allegations that she asserts in the instant case. Attached here to as Exhibit A is Plaintiffs First Amended Complaint filed in the state action. A comparison of the complaint allegations of fact in the state and
+
+federal actions reveals that they are almost identical. Based on the same allegations, in the state action, Plaintiff attempts to assert claims based on state law for Sexual Battery (Count I) and Civil Conspiracy (Count II); in this action, Plaintiff is attempting to assert <sup>a</sup> cause of action pursuant to 18 U.S.C. §2255, which applicable version provides —
+
+#### PART I--CRIMES
+
+### CHAPTER 110--SEXUAL EXPLOITATION AND OTHER ABUSE OF CHILDREN § 2255. Civil remedy for personal injuries
+
+(a) Any minor who is a victim of a violation of section 2241(c), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers persona<sup>l</sup> injury as a result of such violation may sue in any appropriate United States District Court and shall recover the actual damages such minor sustains and the cost of the suit, including areasonable attorney's fee. Any minor as described in the preceding sentence shall be deemed to have sustained damages of no less than \$50,000 in value.
+
+(b) Any action commenced under this section shall be barred unless the complaint is filed within six years after the right of action first accrues or in the case of a person under a legal disability, not later than three years after the disability.
+
+### CREDIT(S)
+
+(Added Pub.L. 99-500, Title I, § 101(b) [Title VII, § 703(a)), Oct. 18, 1986, 100 Stat. 1783-75, and amended Pub.L. 99-591, Title I, § 101(b) [Title VII, § 703(a)], Oct. 30, 1986, 100 Stat. 3341-75: Pub.L. 105-314, Title VI, § 605, Oct. 30, 1998, 112 Stat. 2984.)
+
+(Emphasis added).
+
+Plaintiff is likely to argue that the jurisdiction of the federal court over §2255 claims is exclusive. However, unlike other Congressional enactments, there is no language in the statute which expressly states that jurisdiction of such cause of action lies exclusively with the federal courts. Furthermore, there is a presumption of concurrent jurisdiction of state courts. See generally, Yellow Freight System, Inc. v. Donnelly, <sup>494</sup> U.S. 820, 823, 110 S.Ct. 1566, 1568-69 (1990). "Under our 'system of dual sovereignty, we have consistently held that state courts have inherent authority, and are thus
+
+presumptively competent to adjudicate claims arising under the laws of the United States.'" Id, and cases cited therein. Significantly, in order to give federal courts exclusive jurisdiction over a federal cause of action, Congress must, in an exercise of its powers under the Supremacy Clause, affirmatively divest state courts of their presumptively concurrent jurisdiction. Id.
+
+§2255, unlike other federal statutes, does not unequivocally state that the jurisdiction of the federal court is exclusive or that it takes away the presumptive jurisdiction of the state courts. See e.g., 28 U.S.C. §1338(a)("...Such jurisdiction shall be exclusive of the courts of the states in patent, plant variety protection and copyright cases.") As phrased, the statute uses the term "may" which under a plain meaning analysis is permissive as opposed to mandatory. The omission of any such exclusive jurisdictional provision is strong evidence of Congress' intent. Yellow Freight, supra. The fact that the statute is completely silent on the role of the state courts in such <sup>a</sup> cause of action still does not overcome the presumption of concurrent jurisdiction. Id.'
+
+Because concurrent jurisdiction exists over this federal claim, the six factor analysis as discussed in American Bankers Ins. Co. v. First State Ins. Co., <sup>891</sup>F.2d 882, <sup>884</sup> (11<sup>91</sup> Cir. 1990), applies in determining whether the exceptional circumstances exist requiring dismissal of the federal action in favor of the first filed action. As explained in by the Eleventh Circuit in American Bankers Ins. Co., because EPSTEIN is seeking dismissal of this action in deference to a pending state court action, "it is governed by
+
+<sup>&#</sup>x27; See 45 U.S.C. §56, pertaining to liability for injuries to railroad employees, as an example of <sup>a</sup> federal statute which expressly states that "jurisdiction of the courts of the United States under this chapter shall be concurrent with that of the courts of the several states."
+
+the principles articulated in Colorado River Water Conserv. Dist. v. United States, <sup>424</sup> U.S. 800, 96 S.Ct. 1236, 47 L.Ed.2d 483 (1976) and Moses H. Cone Memorial Hosp. v. Mercury Constr., <sup>460</sup>U.S. 1, 103 S.Ct. 927, 74 L.Ed.2d 765 (1983)."
+
+The six factors considered are (1) whether one of the courts has assumed jurisdiction over property; (2) the inconvenience of the federal forum; (3) the potential for piecemeal litigation; (4) the order in which the forums obtained jurisdiction; (5) whether state or federal law will be applied; and (6) the adequacy of the state court to protect the parties' rights. "The test for determining when exceptional circumstances exist, therefore, involves the careful balancing of six factors. The weight to be given any one factor may vary greatly depending on the case; however, the balance is "heavily weighted" in favor of the federal court exercising jurisdiction. Id. at 16, 103 S.Ct. at 937." American Bankers Ins. Co. of Florida v. First State Ins. Co., <sup>891</sup>F.2d 882, 884 (11th Cir. 1990). The list of factors is neither exhaustive, nor is it a mechanical checklist. See AM.JUR. FED. COURTS, § 1114.
+
+In the instant case, the third, fourth, fifth, and sixth factors are implicated. Clearly, more than a "potential" for piecemeal litigation exists if Plaintiff were allowed to proceed in two separate forums alleging the identical facts against the identical parties. Discovery and rulings thereon would involve the same set of facts, yet could result in inconsistent and varying rulings thereon. Should the cases proceed separately to trial, factual findings and judgments rendered in one could be inconsistent with the other. Appeals would proceed separately and in apiecemeal fashion. The piecemeal effect would be both excessive and deleterious if these cases were to proceed in parallel
+
+fashion. The state court obtained jurisdiction over the action first as Plaintiff chose to first file in state court. See Exhibit A hereto. Defendant has already filed his answer and affirmative defenses and discovery is ongoing in the state action. As to the fifth factor, state law will be applied to Plaintiffs attempted state law claims for sexual battery and conspiracy, while federal substantive law will apply to the 18 U.S.C. §2255 claim. Finally, the state court is perfectly capable and able to protect the rights of the parties. In fact, there are currently before the 15th Judicial Circuit Court, Palm Beach County, Florida, additional cases against EPSTEIN based on similar allegations of sexual exploitation and abuse. In the Jane Doe II state action, an Order was entered reassigning the state action to a Division in which other Jane Doe cases against EPSTEIN had been filed. See "Clerk's Notice Of Reassignment," dated April 10, 2009, and attached hereto as Exhibit B. The state court is well aware of the underlying factual allegations which are identical in both cases and which form the basis of the state and federal' claims which Plaintiff is attempting to pursue.
+
+Accordingly, in balancing these factors, Defendant is entitled to dismissal of the federal court action. Plaintiff should not be allowed to pursue parallel actions in state and federal court based o the identical underlying factual allegations. Her claims should be brought in one forum — state court - so that Defendant is not forced to defend himself in two separate forums.
+
+# II. 18 U.S.C. 42255 in effect prior to the 2006 amendments applies to this action.
+
+A. The statute in effect during the time the alleged conduct occurred is 18 U.S.C. §2255 (2005) - the version in effect prior to the 2006 amendment, eff. Jul. 27, 2006,
+
+(quoted above). See endnote 1 hereto, Complaint ¶¶11, 13.<sup>1</sup> It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf v. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994):
+
+... the presumption against retroactive legislation is deeply rooted in our jurisprudence, and embodies a legal doctrine centuries older than our Republic. Elementary considerations of fairness dictate that individuals should have an opportunity to know what the law is and to conform their conduct accordingly; settled expectations should not be lightly disrupted.<sup>FN18</sup> For that reason, the "principle that the legal effect of conduct should ordinarily be assessed under the law that existed when the conduct took place has timeless and universal appeal." *Kaiser*, 494 U.S., at 855, 110 S.Ct., at 1586 (SCALIA, J., concurring). In a free, dynamic society, creativity in both commercial and artistic endeavors is fostered by a rule of law that gives people confidence about the legal consequences of their actions.
+
+FN18. See *General Motors Corp. v. Romein*, 503 U.S. 181, 191, 112 S.Ct. 1105, 1112, 117 L.Ed.2d 328 (1992) ("Retroactive legislation presents problems of unfairness that are more serious than those posed by prospective legislation, because it can deprive citizens of legitimate expectations and upset settled transactions"); [Further citations omitted].
+
+It is therefore not surprising that the antiretroactivity principle finds expression in several provisions of our Constitution. The *Ex Post Facto* Clause flatly prohibits retroactive application of penal legislation.<sup>FN19</sup> Article I, § 10, cl. 1, prohibits States from passing another type of retroactive legislation, laws "impairing the Obligation of Contracts." The Fifth Amendment's Takings Clause prevents the Legislature (and other government actors) from depriving private persons of vested property rights except for a "public use" and upon payment of "just compensation." The prohibitions on "Bills of Attainder" in Art. I, §§ 9-10, prohibit legislatures from singling out disfavored persons and meting out summary punishment for past conduct. See, e.g., *United States v. ██████████*, 381 U.S. 437, 456-462, 85 S.Ct. 1707, 1719-1722, 14 L.Ed.2d 484 (1965). The Due Process Clause also protects the interests in fair notice and repose that may be compromised by retroactive legislation; a justification sufficient to validate a statute's prospective application under the Clause "may not suffice" to warrant its retroactive application. *Usery v. Turner Elkhorn Mining Co.*, 428 U.S. 1, 17, 96 S.Ct. 2882, 2893, 49 L.Ed.2d 752 (1976).
+
+FN19. Article I contains two *Ex Post Facto* Clauses, one directed to Congress (§ 9, cl. 3), the other to the States (§ 10, cl. 1). We have construed the Clauses as applicable only to penal legislation. See *Calder v. Bull*, 3 Dall. 386, 390-391, 1 L.Ed. 648 (1798) (opinion of Chase, J.).
+
+> These provisions demonstrate that retroactive statutes raise particular concerns. The Legislature's unmatched powers allow it to sweep away settled expectations suddenly and without individualized consideration. Its responsivity to political pressures poses a risk that it may be tempted to use retroactive legislation as a means of retribution against unpopular groups or individuals. As Justice Marshall observed in his opinion for "1498 the Court in Weaver v. Graham, 450 U.S. 24, 101 S.Ct. 960, <sup>67</sup> L.Ed.2d 17 (1981), the Ex Post Facto Clause not only ensures that individuals have "fair warning" about the effect of criminal statutes, but also "restricts governmental power by restraining arbitrary and potentially vindictive legislation." td., at 28-29, <sup>101</sup> S.Ct., at 963-964 (citations omitted). F" 2°
+
+FN20. See Richmond v. J. A. Croson Co., 488 U.S. 469, 513-514, 109 S.Ct. 706, 732, 102 L.Ed.2d 854 (1989) ("Legislatures are primarily policymaking bodies that promulgate rules to govern future conduct. The constitutional prohibitions against the enactment of ex post facto laws and bills of attainder reflect a valid concern about the use of the political process to punish or characterize past conduct of private citizens. It is the judicial system, rather than the legislative process, that is best equipped to identify past wrongdoers and to fashion remedies that will create the conditions that presumably would have existed had no wrong been committed") (STEVENS, J., concurring in part and concurring in judgment); James v. United States, 366 U.S. 213, 247, n. 3, 81 S.Ct. 1052, 1052, n. 3, 6 L.Ed.2d 246 (1961) (retroactive punitive measures may reflect "a purpose not to prevent dangerous conduct generally but to impose by legislation a penalty against specific persons or classes of persons").
+
+As discussed more fully below herein, these well entrenched constitutional protections and presumptions against retroactive application of legislation establish that <sup>18</sup>U.S.C. §2255 (2005) in effect at the time of the alleged conduct applies to the instant action, and not the amended version as claimed by Plaintiff.
+
+B. Not only is there no clear express intent stating that the statute is to apply retroactively, but applying the current version of the statute, as amended in 2006, would be in clear violation of the Ex Post Facto Clause of the United States Constitution as it would be applied to events occurring before its enactment and would increase the penalty or punishment for the alleged crime. U.S. Const. Art. 1, §9, cl. 3, §10, cl. 1. U.S. v. Seigel <sup>153</sup>F.3d 1256 (11th Cir. 1998); U.S. v. , 162 F.3d 87 (3d Cir.
+
+1998); and generally, Calder v. Bull, <sup>3</sup>U.S. 386, 390, 1 L.Ed. 648, 1798 WL <sup>587</sup> (Calder) (1798).
+
+The United States Constitution provides that "[n]o Bill of Attainder or ex post facto Law shall be passed" by Congress. U.S. Const. art. I, § 9, cl. 3. A law violates the Ex Post Facto Clause if it " 'appli[es] to events occurring before its enactment ... [and] disadvantage[s] the offender affected by it' by altering the definition of criminal conduct or increasing the punishment for the crime." Lynce v. Mathis 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997) (quoting Weaver v. Graham <sup>450</sup>U.S. 24, 29, 101 S.Ct. 960, 67 L.Ed.2d 17 (1981)).
+
+U.S. v. Siectel,153 F.3d 1256, 1259 (11th Cir. 1998).
+
+In improperly attempting to multiply the presumptive minimum actual damages amount, Plaintiffs Complaint alleges atime period "from about June, 2003 until on or about February, 2005." See endnote 1. In paragraph 14 of her Complaint, Plaintiff references the 2006 amended version of §2255 which raised the presumptive actual damages amount from \$50,000 to \$150,000; Plaintiff also improperly claims that she is entitled to "\$150,000 for each violation, for a total range of damages between \$1.5 million dollars to \$4.5 million dollars, jointly and severally, ... ." ¶14.
+
+§2255 is contained in Title 18 of the United States Codes - "Crimes and Criminal Procedure, Part I. Crimes, Chap. 110. Sexual Exploitation and Other Abuse of Children." 18 U.S.C. §2255 (2005), is entitled Civil remedy for personal injuries, and imposes a presumptive minimum of damages in the amount of \$50,000, should Plaintiff prove any violation of the specified criminal statutes and that she suffered persona<sup>l</sup> injury with actual damages sustained. Thus, the effect of the 2006 amendments, effective July 27, 2006, would be to triple the amount of the statutory minimum previously in effect during the time of the alleged acts. If one were to take Plaintiff's
+
+position, and multiply the increased damages amount on a per violation/incident basis, the result would be an increase in damages by 30 to 90 times more! Clearly, the result is punitive in nature.
+
+No case has yet decided the specific issue before this Court — whether application of the 2006 version of §2255, which increased the statutorily presumed minimum damages from \$50,000 to \$150,000, regardless of the actual amount of damages sustained, is prohibited from application under the Ex Post Fact Clause to the specified criminal acts occurring prior to the statutes effective date of July 27, 2006. The statute, as amended in 2006, contains no language stating that the application is to be retroactive. Thus, there is no manifest intent that the statute is to apply retroactively, and, accordingly, the statute in effect during the time of the alleged conduct is to apply. Landciraf v. USI Film Products supra, at 1493, ("A statement that a statute will become effective on a certain date does not even arguably suggest that it has any application to conduct that occurred at an earlier date.").
+
+This statute was enacted as part of the Federal Criminal Statutes targeting sexual predators and sex crimes against children. H.R. 3494, "Child Protection and Sexual Predator Punishment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S.C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penalties ever developed in response to crimes against children, particularly assaults facilitated by computers." Further showing that §2255 was enacted as a criminal
+
+penalty or punishment, "Title II — Punishing Sexual Predators," Sec. 206, from House Report No. 105-557, 5-6, specifically includes reference to the remedy created under §2255 as an additional means of punishing sexual predators, along with other penalties and punishments. Senatorial Comments in amending §2255 in 2006 confirm that the creation of the presumptive minimum damage amount is meant as an additional penalty against those who sexually exploit or abuse children. 2006 WL 2034118, 152 Cong. Rec. S8012-02. Senator Kerry refers to the statutorily imposed damage amount as "penalties." Id.
+
+The cases of U.S. v. Siegel supra (11th Cir. 1998), and U.S. v. i supra (3d Cir. 1998), also support Defendant's position that application of the current version of 18 U.S.C. §2255 would be in clear violation of the Ex Post Facto Clause. In Siegel, the Eleventh Circuit found that the Ex Post Facto Clause barred application of the Mandatory Victim Restitution Act of 1996 (MVRA) to the defendant whose criminal conduct occurred before the effective date of the statute, 18 U.S.C. §3664(f)(1)(A), even though the guilty plea and sentencing proceeding occurred after the effective date of the statute. On July 19, 1996, the defendant Siegel pleaded guilty to various charges under 18 U.S.C. §371 and §1956(a)(1)(A), (conspiracy to commit mail and wire fraud, bank fraud, and laundering of money instruments; and money laundering). He was sentenced on March 7, 1997. As part of his sentence, Siegel was ordered to pay \$1,207,000.00 in restitution under the MVRA which became effective on April 24, 1996. Pub.L. No. 104-132, 110 Stat. 1214, 1229-1236. The 1996 amendments to MVRA required that the district court must order restitution in the full amount of the victim's loss
+
+Page 12
+
+without consideration of the defendant's ability to pay. Prior to the enactment of the MVRA and under the former 18 U.S.C. §3664(a) of the Victim and Witness Protection Act of 1982 (VWPA), Pub.l. No. 97-291, 96 Stat. 1248, the court was required to consider, among other factors, the defendant's ability to pay in determining the amount of restitution.
+
+When the MVRA was enacted in 1996, Congress stated that the amendments to the VWPA "shall, to the extent constitutionally permissible, be effective for sentencing proceedings in cases in which the defendant is convicted on or after the date of enactment of this Act [Apr. 24, 1996]." Siegel, supra at 1258. The alleged crimes occurred between February, 1988 to May, 1990. The Court agreed with the defendant's position that 1996 MVRA "should not be applied in reviewing the validity of the court's restitution order because to do so would violate the Ex Post Facto Clause of the United States Constitution. See U.S. Const. art I, §9, cl. 3."
+
+The Ex Post Facto analysis made by the Eleventh Circuit in Siegel is applicable to this action. In resolving the issue in favor of the defendant, the Court first considered whether a restitution order is a punishment. Id, at 1259. In determining that restitution was <sup>a</sup>punishment, the Court noted that §3663A(a)(1) of Title 18 expressly describes restitution as <sup>a</sup>"penalty? In addition, the Court also noted that "[ajlthough not in the context of an ex post facto determination, ... restitution is a 'criminal penalty meant to have strong deterrent and rehabilitative effect.' United States v. Twittv <sup>107</sup>F.3d 1482, <sup>1493</sup>n. 12 (11th Cir.1997)." Second, the Court considered "whether the imposition of restitution under the MVRA is an increased penalty as prohibited by the Ex Post Facto
+
+Clause." Id, at 1259. In determining that the application of the 1996 MVRA would indeed run afoul of the Constitution's Ex Post Facto Clause, the Court agreed with the majority of the Circuits that restitution under the 1996 MVRA was an increased penalty.<sup>2</sup> "The effect of the MVRA can be detrimental to a defendant. Previously, after considering the defendant's financial condition, the court had the discretion to order restitution in an amount less than the loss sustained by the victim. Under the MVRA, however, the court must order restitution to each victim in the full amount." Id, at 1260. See also U.S. v. 162 F.2d 87 (3rd Circuit 1998).
+
+In the instant case, in answering the first question, it is clear that that imposition of <sup>a</sup>minimum amount of damages, regardless of the amount of actual damages suffered by aminor victim, is meant to be a penalty or punishment. See statutory text and House Bill Reports, cited above herein, consistently referring to the presumptive minimum damages amount under §2255 as "punishment" or "penalties." According to the Ex Post Facto doctrine, although §2255 is labeled a "civil remedy," such label is not dispositive; "if the effect of the statute is to impose punishment that is criminal in nature, the ex post facto clause is implicated." See generally, Roman Catholic of Oakland v. Superior Court <sup>28</sup>Cal.Rptr.3d 355, at 360, citing Kansas v. Hendricks <sup>521</sup> U.S. 346, 360-61 (1997). The effect of applying the 2006 version of §2255 would be to triple the amount of the presumptive minimum damages to a minor who proves the
+
+The Eleventh Circuit, in holding that "the MVRA cannot be applied to a person whose criminal conduct occurred prior to April 24, 1996," was "persuaded by the majority of districts on this issue." "Restitution is a criminal penalty carrying with it characteristics of criminal punishment." Siegel, supra at 1260. The Eleventh Circuit is in agreement with the Second, Third, Eighth, Ninth, and D.C. Circuits. See U.S. v. Futrell, <sup>209</sup>F.3d 1286, 1289-90 (11th Cir. 2000).
+
+Jane Doe II v. Epstein, et at
+
+Page 14
+
+elements of her §2255 claim, or to increase to it 30 to 90 times more if one were to agree with Plaintiff's position. The fact that a plaintiff proceeding under §2255 has to prove a violation of a criminal statute and suffer personal injury to recover damages thereunder, further supports that the imposition of a minimum amount, regardless of <sup>a</sup> victim's actual damages sustained, is meant and was enacted as additional punishment or penalty for violation of criminal sexual exploitation and abuse of minors.
+
+Accordingly, this Court is required to apply the statute in effect at the time of the alleged criminal acts. Not only is there no language in the 2006 statute stating that it is to apply retroactively, but further, such application of the 2006 version of 18 U.S.C. §2255 to acts that occurred prior to its effective date would have a detrimental and punitive effect on Defendant by tripling (or increasing by 30 or 90 times under Plaintiffs interpretation) the presumptive minimum of damages available to a plaintiff, regardless of the actual damages suffered.
+
+C. As discussed above, 18 U.S.C. §2255 was enacted as part of the criminal statutory scheme to punish and penalize those who sexually exploit and abuse minors, and thus, the Ex Post Fact Clause prohibits aretroactive application of the <sup>2006</sup> amended version. Even under the analysis provided by the United States Supreme Court in Landqraf v. USI Film Products, <sup>511</sup>U.S. 244, 114 S.Ct. 1483 (1994), pertaining to civil statutes, not only is there no express intent by Congress to apply the new statute to past conduct, but also, the clear effect of retroactive application of the statute would be to increase the potential liability for past conduct from a minimum of \$50,000 to \$150,000, and thus in violation of the constitutional prohibitions against such
+
+application. As noted, 18 U.S.C. §2255 is entitled "Civil remedy for personal injuries." Notwithstanding this label, the statute was enacted as part of the criminal statutory scheme to punish those who sexually exploit and abuse minors. Regardless of the actual damages suffered or proven by a minor, as long as a minor proves violation of a specified statutory criminal act under §2255 and personal injury, the defendant is held liable for the statutory imposed minimum.
+
+As explained by the Landoraf court, supra at 280, and at 1505,3
+
+When a case implicates a federal statute enacted after the events in suit, the court's first task is to determine whether Congress has expressly prescribed the statute's proper reach. If Congress has done so, of course, there is no need to resort to judicial default rules. When, however, the statute contains no such express command, the court must determine whether the new statute would have retroactive effect, i.e., whether it would impair rights a party possessed when he acted, increase a party's liability for past conduct, or impose new duties with respect to transactions already completed. If the statute would operate retroactively, our traditional presumption teaches that it does not govem absent clear congressional intent favoring such a result.
+
+Here, there is no clear expression of intent regarding the 2006 Act's application to conduct occurring well before its enactment. Clearly, however, as discussed in part B herein, the presumptive minimum amount of damages of \$150,000 was enacted as an punishment or penalty upon those who sexually exploit and abuse minors. See discussion of House Bill Reports and Congressional background above herein. The amount triples the previous amount for which a defendant might be found liable, regardless of the amount of actual damages a plaintiff has suffered and proven. The new
+
+<sup>3</sup> In Landqraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before the effective date of the Act. The Court determined that statutory text in question, §102, was subject to the presumption against statutory retroactivity.
+
+statute imposes a substantial increase in the monetary liability for past conduct. (As discussed below, Plaintiff also proposes that the minimum damage amount is to apply on a per violation basis; the absurdity of such position is further magnified when one considers that the presumptive damages amount was tripled to \$150,000).
+
+As stated in Landqraf, "the extent of a party's liability, in the civil context as well as the criminal, is an important legal consequence that cannot be ignored." Courts have consistently refused to apply astatute which substantially increases a party's liability to conduct occurring before the statute's enactment. Landarat, supra at 284-85. Even if plaintiff were to argue that retroactive application of the new statute "would vindicate its purpose more fully," even that consideration is not enough to rebut the presumption against retroactivity. Id, at 285-86. "The presumption against statutory retroactivity is founded upon sound considerations of general policy and practice, and accords with long held and widely shared expectations about the usual operation of legislation." Id.
+
+Accordingly, this Court is required to apply the statute in effect at the time of the alleged conduct. 18 U.S.C. §2255 (2005).
+
+# III. Standard - Motion To Dismiss, More Definite Statement, Pleading, & Motion to Strike
+
+As established by the Supreme Court in Bell Atlantic Corp. V. Twombly, <sup>127</sup> S.Ct. 1955 (2007), amotion to dismiss should be granted if the plaintiff does not plead "enough facts to state a claim to relief that is plausible on its face." Id, at 1974. Although the complaint need not provide detailed factual allegations, the basis for relief in the complaint must state "more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do." Id at 1965. Further, "Wactual
+
+allegations must be enough to raise a right to relief above the speculative level ... on the assumption that all the allegations in the complaint are true (even if doubtful in fact)." Id. On a motion to dismiss, the well pleaded allegations of plaintiff's complaint are taken as true and construed in the light most favorable to the plaintiff. M.T.V. v. DeKalb County Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006).
+
+In discussing Twombly, the Eleventh Circuit in v. Fla. International Univ. <sup>495</sup>F.3d 1289, 1295 (11th Cir. 2007), noted - "The Supreme Court's most recent formulation of the pleading specificity standard is that 'stating such a claim requires <sup>a</sup> complaint with enough factual matter (taken as true) to suggest' the required element." In order to sufficiently allege the claim, the complaint is required to identify "facts that are suggestive enough to render [the element] plausible." , 495 F.3d at <sup>1296</sup> (quoting Twombly, <sup>127</sup>S.Ct. at 1965).
+
+Pursuant to Rule 12(e), a party may move for more definite statement of <sup>a</sup> pleading to which a responsive pleading is allowed where the pleading "is so vague or ambiguous that the party cannot reasonably frame a response." The motion is required to point out the defects and the desired details. Id. As to the general rules and form of pleading, Rules 8 and 10, aclaim for relief must contain "a short plain statement of the claim showing that the pleader is entitled to relief;" Rule 8(a)(3); and may contain alternative claims within a count or as many separate claims. Rule 10(d)(2) and (3).
+
+## A. 18 U.S.C. V255(a) does not allow the Plaintiff to multiple the presumptive minimum damages amount on a per incident or per violation basis.
+
+In attempting to allege a §2255 claim, Plaintiff alleges that she is entitled to <sup>a</sup> multiplication of the presumptive minimum damages amount based on the number of
+
+incidents. See endnote 1, Complaint, ¶¶13-14. Under the plain meaning of the statutory text, §2255 does not allow for a multiplication of the presumptive "actual damages" by the number of incidents or violations alleged. No where in the statutory text is there any reference to the "civil remedy" afforded against adefendant by this statute as being on <sup>a</sup>"per violation" or "per incident" basis. 18 U.S.C. 2255(a) creates <sup>a</sup> "civil remedy" for "a minor who is a victim of a violation of section 2241(c), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal injury as a result of such violation ... ." The presumptive minimum damages amount speaks in terms of "actual damages." See 18 U.S.C. §2255 (2005), quoted above in part I; v. Husband, <sup>428</sup>F.Supp.2d 432 (E.D. Va. 2006); lEry, Husband <sup>376</sup>F.Supp.2d 603 (E.D. Va. 2006); Doe v. Liberatore, <sup>478</sup>F.Supp.2d 742, <sup>754</sup>(M.D. Pa. 2007); and the recent cases in front of this court on Defendant's Motions to Dismiss and For More Definite Statement — Doe No. 2 v. Epstein, <sup>2009</sup>WL <sup>383332</sup> (S.D. Fla. Feb. 12, 2009); Doe No. 3 v. Epstein, <sup>2009</sup>WL 383330 (S.D. Fla. Feb. 12, 2009); Doe No. 4 v. Epstein, <sup>2009</sup>WL 383286 (S.D. Fla. Feb. 12, 2009); and Doe No. <sup>5</sup> v. Epstein, <sup>2009</sup>WL 383383 (S.D. Fla. Feb. 12, 2009).
+
+There is no reported case supporting Plaintiffs tortured and nonsensical interpretation of §2255. In all of these cases (cited above), each of the Plaintiffs brought <sup>a</sup>single count or cause of action attempting to allege numerous violations of the "predicate acts" specifically identified in §2255; in none of the cases did the Court award the presumptive amount of damages based on a per incident or per violation basis. "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action."
+
+v. 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007), (emphasis added). <sup>18</sup> U.S.C.A. §2255 "merely provides acause of action for damages in 'any appropriate United States District Court.'" Id, at 1189. In Tilton v. Playboy Entertainment Group<sup>s</sup> Inc., 554 F.3d 1371 (11th Cir. Jan. 15, 2009), the District Court granted plaintiff "the minimum 'actual damages' prescribed by §2255(a)," wherein plaintiff alleged that defendants had violated three of the statutory predicate acts; there was no multiplying of the award.
+
+It is well settled that in interpreting a statute, the court's inquiry begins with the plain and unambiguous language of the statutory text. CBS, Inc. v. Prime Time <sup>24</sup> Venture, <sup>245</sup>F.3d 1217 (11th Cir. 2001); U.S. v. Castroneves, <sup>2009</sup>WL 528251, \*3 (S.D. Fla. 2009), citing Reeves v. Astrue, <sup>526</sup>F.3d 732, 734 (11th Cir. 2008); and v. Husband <sup>376</sup>F.Supp.2d at 610 ("When interpreting a statute, [a court's] inquiry begins with the text."). "The Court must first look to the plain meaning of the words, and scrutinize the statute's 'language, structure, and purpose.'" Id. In addition, in construing <sup>a</sup>statute, acourt is to presume that the legislature said what it means and means what it said, and not add language or give some absurd or strained interpretation. As stated in CBS. Inc supra at 1228 — "Those who ask courts to give effect to perceived legislative intent by interpreting statutory language contrary to its plain and unambiguous meaning are in effect asking courts to alter that language, and '[c]ourts have no authority to alter statutory language.... We cannot add to the terms of [the] provision what Congress left out.' Merritt, 120 F.3d at 1187." See also Dodd v. U.S., <sup>125</sup>S.Ct. 2478 (2005); 73 Am.Jur.2d Statutes §124.
+
+As quoted above, Title 18 of the U.S.C. is entitled "Crimes and Criminal Procedure." §2255 is contained in "Part I. Crimes, Chap. 110. Sexual Exploitation and Other Abuse of Children." 18 U.S.C. §2255 (2003), is entitled Civil remedy for persona<sup>l</sup> injuries. Reading the entire statute in context, no where is there any language indicating that presumptive minimum damages amount is to be multiplied on <sup>a</sup>"per violation" or "per incident basis." Under the statutory rules of construction, had the legislature intended to include a multiplier with respect to the damages amount, the statute would have included such language. Had Congress wanted to create such <sup>a</sup> remedy as Plaintiff attempts to bring, it could have easily included language of "such damages shall be multiplied on a per violation" or "per incident" basis in subsection (a).
+
+By its own terms, the statute provides for the recovery of "actual damages the minor sustains and the cost of the suit, including attorney's fees." The next sentence expressly states — "Any minor as described in the preceding sentence shall be deemed to have sustained damages of no less than \$50,000 in value." (Even the <sup>2006</sup> amended version provides — "Any person as described in the preceding sentence shall be deemed to have sustained damages of no less than \$150,000 in value.") There is absolutely no language that allows for a plaintiff to multiply the specified or presumptive damages recoverable on <sup>a</sup>"per violation" or "per incident" basis. The Plaintiffs position on §2255 puts astrained interpretation with an absurd result.
+
+In v. , supra, the defendants sought to dismiss plaintiffs' 18 U.S.C. §2255 action based on forum non conveniens. The Northern District of California Court, relying on the rules of statutory construction, rejected plaintiffs' argument that Congress
+
+had intended to abrogate the forum non conveniens doctrine in a§2255 action; the District Court noted that the statute does not contain a mandatory venue provision. Had Congress wanted to get rid of the forum non-conveniens doctrine, it would have said so in the statute. Also, in v. Husband, 428 F.Supp. 432; and 376 F.Supp.2d 603, the plaintiff invoked "the accompanying civil remedy for these criminal violations, stating that she has sustained and continues to sustain physical and mental damages, humiliation, and embarrassment as a result of Defendant's criminal acts." In other words, she brought a single cause of action, based on allegations of multiple violations of the §2255 predicate acts. Furthermore, the court refused to add a venue interpretation that simply was not written into the statutory text. See other §2255 cases cited herein.
+
+For an example of a statute wherein the legislature included the language "for each violation" in assessing a"civil penalty," see 18 U.S.C. §216, entitled "Penalties and injunctions," of Chapter 11 - "Bribery, Graft, and Conflict of Interests," also contained in Title 18 - "Crimes and Criminal Procedure." Subsection (b) of §216 gives the United States Attorney General the power to bring a"civil action ... against any person who engages in conduct constituting an offense under" specified sections of the bribery, graft, and conflicts of interest statutes. The statute further provides in relevant part that "upon proof of such conduct by a preponderance of the evidence, such person shall be subject to a civil penalty of not more than \$50,000 for each violation or the amount of compensation which the person received or offered for the prohibited conduct, which ever amount is greater." As noted, 18 U.S.C. §2255 does not include such language.
+
+Accordingly, Plaintiff has failed to allege acause of action under §2255, as the statute does not allow for the multiplication of the presumptive damages amount on <sup>a</sup> per incident or per violation basis. Plaintiff Complaint is required to be dismissed.
+
+#### B. Also requiring dismissal Plaintiff has failed to sufficiently allege any requisite V265 predicate act.
+
+Also requiring dismissal of Plaintiffs purported §2255 claim is Plaintiffs failure to sufficiently allege any violation of a requisite predicate act as specifically identified in subsection (a). Relevant to Plaintiff's complaint, 18 U.S.C. 2255(a) creates a cause of action for "a minor who is a victim of a violation of section 2241(c), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers persona<sup>l</sup> injury as a result of such violation ... ." See cases cited above herein. The referenced statutes are criminal statues all contained in Title 18. In paragraph 13 and 15, Plaintiff makes reference by citation only to "18 U.S.C. §2422(b)." See endnote 2 for the complete statutory text.<sup>2</sup> See also this Court's recent orders on motions to dismiss in other actions filed against EPSTEIN by "Jane Does," Case Nos: 08-CV-80119- MARRAMMI; 08-CV-80232-MARRA-M.; and 08-CV-80380-MARRArequiring sufficient allegations of predicate acts.
+
+<sup>A</sup>reading of §2422(b) shows that no where in Plaintiff Complaint are there any allegations setting forth the requisite elements of the cited predicate act. See Mi. Husband, <sup>376</sup>F.Supp.2d, and 428 Supp.2d, supra; and Gray v. Darby <sup>2009</sup>WL <sup>805435</sup>(E.D. Pa. Mar. 25, 2005), requiring allegations/evidence to establish predicate act under 18 U.S.C. §2255 to state cause of action. There are no allegations what so ever regarding EPSTEIN "using the mail or any facility or means of interstate or foreign
+
+commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, ... ."
+
+Plaintiff appears to be relying solely on an "agreement with the United States Attorney's Office to not contest liability for claims brought exclusively pursuant to <sup>18</sup> U.S.C. §2255, in exchange for avoiding federal prosecution under 18 U.S.C. §2422(b)." Complaint, ¶15. As noted above herein, Plaintiff already has additional claims against EPSTEIN pending in state court. See Exhibit A hereto. Even taking Plaintiffs allegation in paragraph 15 as true, Plaintiff is not proceeding exclusively under §2255. Accordingly, under the standard of pleading as established in Twombly, supra, Plaintiff has failed to sufficiently allege the requisite elements of a §2255 claim, thus requiring dismissal for failure to state a cause of action.
+
+C. In the alternative, pursuant to constitutional law principles of statutory interpretation, 18 U.S.C. §225S is required to be interpreted as creating <sup>a</sup> single "civil remedy" or cause of action on behalf of a minor plaintiff against adefendant. The "civil remedy" afforded is not on <sup>a</sup>"per violation" or "per incident" basis.
+
+As set forth above, it is Defendant's position that the text of 18 U.S.C. §2255 does not allow a Plaintiff to pursue the damages afforded under the statute on <sup>a</sup>"per violation" or "per incident" basis. In the alternative, if one were to assume that the language of §2255 were vague or ambiguous, under the constitutional based protections of due process, judicial restraint, and the rule of lenity applied in construing <sup>a</sup>statute, Defendant's position as to the meaning of the statute would prevail over
+
+Plaintiffs view. See United States v. , 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in , supra, at 2025:
+
+... The rule of lenity requires ambiguous criminal laws to be interpreted in favor of the defendants subjected to them. See United States v. Gradwell, <sup>243</sup>U.S. 476, 485, 37 S.Ct. 407, 61 L.Ed. 857 (1917); McBoyle v. United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); United States v. Bass, 404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (1971). This venerable rule not only vindicates the fundamental principle that no citizen should be held accountable for a violation of a statute whose commands are uncertain, or subjected to punishment that is not clearly prescribed. It also places the weight of inertia upon the party that can best induce Congress to speak more clearly and keeps courts from making criminal law in Congress's stead. ...
+
+In the Court was faced with the interpretation of the term "proceeds" in the federal money laundering statute, 18 U.S.C. §1956. "The federal money-laundering statute prohibits anumber of activities involving criminal 'proceeds.'" Id, at 2023. Noting that the term "proceeds" was not defined in the statute, the Supreme Court stated the well settled principle that "when a term is undefined, we give it its ordinary meaning." Id, at 2024. Under the ordinary meaning principle, the government's position was that proceeds meant "receipts," while the defendant's position was that proceeds meant "profits." The Supreme Court recognized that under either of the proffered "ordinary meanings," the provisions of the federal money-laundering statute were still coherent, not redundant, and the statute was not rendered "utterly absurd." Under such <sup>a</sup> situation, citing to a long line of cases and the established rule of lenity, "the tie must go to the defendant." Id, at 2025. See portion of Court's opinion quoted above. "Because the 'profits' definition of 'proceeds' is always more defendant friendly that the 'receipts' definition, the rule of lenity dictates that it should be adopted." Id.
+
+Plaintiffs position would subject Defendant EPSTEIN to a punishment that is not clearly prescribed — an unwritten multiplier of the "actual damages" or the presumptive minimum damages. The rule of lenity requires that Defendant's interpretation of the remedy afforded under §2255 be adopted. As noted above, Plaintiffs interpretation would allow Plaintiff to multiply her recovery without any regard to what the actual damages are.
+
+In addition, under the Due Process Clause's basic principle of fair warning -
+
+... a criminal statute must give fair warning of the conduct that it makes <sup>a</sup> crime ... . As was said in United States v. Harriss, <sup>347</sup>U.S. 612, 617, <sup>74</sup> S.Ct. 808, 812, 98 L.Ed. 989,
+
+'The constitutional requirement of definiteness is violated by acriminal statute that fails to give a person of ordinary intelligence fair notice that his contemplated conduct is forbidden by the statute. The underlying principle is that no man shall be held criminally responsible for conduct which he could not reasonably understand to be proscribed.'
+
+Thus we have struck down a [state] criminal statute under the Due Process Clause where it was not 'sufficiently explicit to inform those who are subject to it what conduct on their part will render them liable to its penalties.' Connally v. General Const. Co., 269 U.S. 385, 391, 46 S.Ct. 126, 127, <sup>70</sup> L.Ed. 322. We have recognized in such cases that 'a statute which either forbids or requires the doing of an act in terms so vague that men of common intelligence must necessarily guess at its meaning and differ as to its application violates the first essential of due process of law,' ibid., and that 'No one may be required at peril of life, liberty or property to speculate as to the meaning of penal statutes. All are entitled to be informed as to what the State commands or forbids.' Lanzetta v. New Jersey, 306 U.S. 451, 453, <sup>59</sup> S.Ct. 618, 619, 83 L.Ed. 888.
+
+Thus, applying these well-entrenched constitutional principles of statutory interpretation and application, Plaintiffs cause of action attempting to multiply the presumptive amount of damages is required to be dismissed for failure to state a cause of action.
+
+### D. Plaintiffs action is also required to be dismissed for failure to state a cause of action sounding in conspiracy under §2255.
+
+Finally, Plaintiffs entire action is subject to dismissal to the extent that she is attempting to allege a conspiracy to violate §2255 for the same reasons she has failed to state a cause of action against EPSTEIN individually as discussed above herein. See Complaint ¶¶9, 10, 11, 13, and 14.
+
+#### Conclusion
+
+Plaintiff improperly relies on the 18 U.S.C. §2255, as amended, eff, July 27, 2006, in her attempt to plead acause of action. The statue in effect during the time of the alleged conduct applies. Plaintiff has also improperly sought to multiply the presumptive minimum damages amount imposed on a per incident or per violation basis. Not only is there nothing in the statute which would allow for such interpretation, but such interpretation is in violation of well established constitutional principles. Finally, Plaintiff has failed to state a cause of action under §2255 either individually against EPSTEIN or as <sup>a</sup>conspiracy. There are absolutely no underlying factual allegations setting forth the elements of the predicate act relied upon.
+
+WHEREFORE, Defendant respectfully requests that this Court dismiss Plaintiff's entire action.
+
+> By: ROBERT D RITTON, JR., ESQ. Florida Bar o. 224162 rcritabcIclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpikeAbciclaw.com
+
+#### Certificate of Service
+
+<sup>I</sup>HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following service list in the manner pecified via transmission of Notices of Electronic Filing generated by CM/ECF on this day of , 2009:
+
+ro M. IS , Esq. Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidrogarciaatellsouth.net 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 561-835-8691 Fax jaqescabellsouth.net Co-Counsel for Defendant Jeffrey Epstein
+
+Respectfully sub
+
+By: ROBERT D. ITTON, JR., ESQ. Florida Bar .. 224162 rcrita,bcIcla .com MICHAEL J. PIKE, ESQ. Florida Bar #617296 moike bcIclaw.com BURMAN, CRITTON, LUTHER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561-842-2820 Fax: 561-515-3148 (Co-counsel for Defendant Jeffrey Epstein)
+
+#### ENDNOTES:
+
+In paragraph 11 of her Complaint, Jane Doe II alleges rom about June, <sup>2003</sup> until about February, 2005, Defendants, EPSTEIN and persuaded, induced, or
+
+enticed Plaintiff to come to Defendant EPSTEIN's home and provide Defendant EPSTEIN with 'massages' ... ."
+
+In pars Jane Doe II alleges — "In violation of §2422(b), Defendants EPSTEIN and knowingly persuaded, induced, or enticed the Plaintiff to engage in acts of prostitution, when the Plainitff was undr the age of 18, approximately on or about the following dates that Plaintiff can document based on payments received: 6/16/03, 7/2/03, 4/9/04, 6/7/04, 7/30/04, 8/30/04, 10/9/04, 10/12/04 and 11/9/04. In addition, Plaintiff believes that there were as many as 10 to 20 other occasions during this time frame that Defendant EPSTEIN solicited her and procured her to perform prostitution services, all during the time that she was a minor."
+
+In paragraph 14, Plaintiff alleges — "Plaintiff seeks damages for personal injury in accordance with 18 U.S.C. §2255(a) for each of the acts of prostitution set forth above which Defendants solicited her, \$150,000 for each violation, for a total range of damages between \$1.5 million dollars and \$4.5 million dollars, jointly and severally, and <sup>a</sup>reasonable attorney's fees and costs, as permitted by the statute."
+
+2
+
+### TITLE 18. CRIMES AND CRIMINAL PROCEDURE PART I-CRIMES CHAPTER 117--TRANSPORTATION FOR ILLEGAL SEXUAL ACTIVITY AND RELATED CRIMES § 2422. Coercion and enticement
+
+(a) Whoever knowingly persuades, induces, entices, or coerces any individual to travel in interstate or foreign commerce, or in any Territory or Possession of the United States, to engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall be fined under this title or imprisoned not more than 20 years, or both.
+
+(b) Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of <sup>18</sup>years, to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall be fined under this title and imprisoned not less than 5 years and not more than 30 years.
+
+### CREDIT(S)
+
+(June 25, 1948, c. 645, 62 Stat. 812; Nov. 7, 1986, Pub.L. 99-628, § 5(b)(1), 100 Stat. 3511; Nov. 18, 1988, Pub.L. 100-690, Title VII, § 7070, 102 Stat. 4405; Feb. 8, 1996, Pub.L. 104-104, Title V, § 508, 110 Stat. 137; Oct. 30, 1998, Pub.L. 105-314, Title I, §
+
+102, 112 Stat. 2975; Apr. 30, 2003, Pub.L. 108-21, Title I, § 103(a)(2)(A), (B), (b)(2)(A), 117 Stat. 652, 653.)
+
+# Amendments
+
+2006 Amendments. Subsec. (b). Pub.L. 109-248, § 203, struck out "not less than 5 years and not more than 30 years" and inserted "not less than 10 years or for life".

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marker2/court-doe-v-epstein-80469/EFTA02750376/EFTA02750376.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 3,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80119-MARRA
+
+CASE NO.: 013-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 1 -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 CONSOLIDATING CASES FOR PURPOSES OF DISCOVERY AND PROCEDURAL MOTIONS THAT RELATE TO MULTIPLE CASES
+
+THIS CAUSE is before the Court sua sponte. In the interests of judicial economy and
+
+efficiency, it is hereby ORDERED AND ADJUDGED as follows:
+
+I. The above-styled cases are hereby CONSOLIDATED for purposes of discovery and for procedural motions that relate to multiple cases.
+
+2. Hereinafter, all motions and other court filings that relate to discovery and all procedural motions that relate to multiple cases shall be styled with all of the case names and numbers, consistent with the styling of this Order, and shall be FILED ONLY IN Jane Doe No. 2 v. Epstein, case no. 08-80119, which is the lowest-numbered pending case. Any motions styled incorrectly or filed in multiple cases will be stricken from the docket for failure to follow the Court's Order.
+
+3. The parties may file separate motions to dismiss, answers to the complaint, summary judgment motions, motions in limine and other substantive motions that pertain to their individual cases and their individual trials under their individual case styles.
+
+4. Production of documents by any party or non-party that relate to multiple cases need be produced only once.
+
+5. Defendant is limited to a single deposition of each Plaintiff, during which Defendant may depose the Plaintiff as both a party and a witness.
+
+6. Defendant(s) may be deposed only once.
+
+7. Any other witnesses common to multiple cases may be deposed only once.
+
+8. For depositions, Local Rule 26.1 K (limiting deposition time to one day of seven hours) is waived so as to allow each party an adequate opportunity to develop fully the record as it may relate to that party. However, this waiver shall not be construed as authority for any party to take unnecessarily long depositions, or abuse the process. Any abuses of this waiver
+
+shall result in the imposition of appropriate sanctions against the offending party.
+
+**DONE AND ORDERED** in [REDACTED] at West Palm Beach, Palm Beach County,
+
+Florida, this 14<sup>th</sup> day of May, 2009
+
+![]()
+
+---
+
+KENNETH A. MARRA  
+United States District Judge
+
+Copies furnished to:
+
+all counsel of record
+
+Magistrate Judge Linnea R. [REDACTED]

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marker2/court-doe-v-epstein-80469/EFTA02750381/EFTA02750381.md

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+**UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF FLORIDA**
+
+**CASE NO.: 08-CV-80811-MARRA/ [REDACTED]**
+
+C.M. A.,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN and [REDACTED]  
+[REDACTED],
+
+Defendants,
+
+**Defendant, Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law**
+
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing this action for a time certain (i.e., until late 2010 when the NPA expires), pursuant to the application of the Fifth Amendment of the U.S. Constitution and the fact that a parallel proceeding is ongoing and being investigated. In support of his motion, EPSTEIN states:
+
+**I. Introduction**
+
+At the outset, EPSTEIN notes this Court's prior Order, dated December 16, 2008, (Document 28), in which this Court denied a motion for stay brought by Defendant's prior counsel. In that instance, Defendant's counsel requested a mandatory stay under 18 U.S.C.A. §3509(k) which the court denied. In denying the request for the stay, this Court stated that a discretionary stay was not appropriate at the time the order was entered but also stated, in part, that "Any such issues shall be resolved as they arise in the course of litigation." As discussed herein, "special circumstances" now exist which, in the "interests of justice," merit the entry of a stay of this civil action until the criminal matter in the 15<sup>th</sup> Judicial Circuit is "closed" in
+
+accordance with the United States Attorney's Office ("USAO") Non-Prosecution Agreement ("NPA") and until the NPA expires.
+
+Moreover, EPSTEIN was indicted by a grand jury in or around July 2006. See Exhibit "A". The Non-Prosecution Agreement is part of the record in connection with that indictment, which is signed by the State Attorney of the 15th Judicial Circuit in and for Palm Beach County, Florida ("SAO"). In fact, the NPA acknowledges the investigation performed by the SAO. Further, the USAO was present at the Plea hearing whereby the NPA was made part of the record. Thus, there is no question that a parallel criminal matter exists in that the SAO's case remains open and the NPA lives along side it, which places EPSTEIN under grea<sup>t</sup>scrutiny by the USAO. The NPA actually places an affirmative duty upon EPSTEIN to undertake discussions with the SAO to ensure compliance with the NPA. That check and balance, therefore, remains in the hands of the SAO, which has a parallel criminal proceeding. Here, the threat of prosecution is real, substantial, and present should the USAO determine that EPSTEIN somehow violated the NPA. As discussed below, because the NPA fails to define what constitutes a breach, the USA() has apparently taken it upon itself to determine whether abreach has occurred and whether to seek criminal prosecution. In fact, the USAO has already attempted to claim violations of the NPA due to, among other things, EPSTEIN defending the civil actions against him. Clearly, it is NOT simply EPSTEIN's choice as to whether he violates the NPA — that discretion apparently lies with the USAO. For this reason alone, a stay is required until the NPA expires.
+
+The difference between this Motion and the prior motion to stay is solely due to the ripeness of the issues discussed herein.
+
+# H. THE NPA
+
+By its terms, the NPA took effect on June 30, 2008 and expires by those same terms in late 2010 so long as EPSTEIN complies with the terms and conditions — violations of which remain undefined. The NPA, which remains under seal, outlines various obligations on the part of EPSTEIN including, but not limited to, pleading guilty to the Indictment and Information before the 15th Judicial Circuit, recommendations for his sentencing before the 15th Judicial Circuit, waiver of challenges to the Information filed by the SAO, waiver of right to appeal his conviction, agreement not be afforded benefits for gain time, and the agreement to not prosecute others listed thereon so long as EPSTEIN does not breach and fulfills the requirements of the NPA.
+
+What the NPA does not outline or define is what constitutes a breach or what act or omission constitutes a breach thereof. Therefore, the USAO apparently believes it has the discretion to make that unwritten and undefined determination, which places an unreasonable burden upon EPSTEIN in defending the civil claims in that he has no idea what the USAO will define as a breach in the event he does not assert his 51° Amendment Rights. As an example, the USAO has already claimed that EPSTEIN violated the NPA by:
+
+- 1. investigating the Plaintiffs (by and though his attorneys) whom brought civil suits against him for purposes of defending those civil actions;
+  - 2. contesting damages in this action and in the other civil actions;
+- 3. making statements to the press about this Plaintiff or other Plaintiffs by and though his attorneys; and
+
+4. using the word "jail" instead of "imprisonment" in the plea agreement with SA's office.
+
+See Exhibit "B" Goldberger Affidavit - EPSTEIN's criminal counsel.
+
+These allegations are silly, unfounded and alleged violations which are not defined as violations under the NPA but arrived at by the USAO. Thus, EPSTEIN is left with "Morton's Fork" in his side - the undesirable choice of taking the 5h Amendment and having a judgment (summary or otherwise) entered against him in the civil action or the undesirable choice of subjecting himself to discovery in the civil action before the NPA expires and, thus, face the possibility of criminal prosecution by the USAO based upon some illusory breach deemed by the USAO by way of information obtained through civil discovery proceedings. This is inherently unfair, the danger is clear, and the playing field is not level in light of the NPA language or lack thereof.
+
+As a result, the threat of criminal prosecution against EPSTEIN by the USAO continues presently and through late 2010.
+
+### III, Justice Requires The Entry of A Stay Because Defendant Is Being Forced To Choose Between Waiving His 51h Amendment Privilege Or Risk Losing This Civil Case And Forfeiting Other Constitutional Guarantees Of Due Process And Effective Assistance Of Counsel
+
+Once the NPA expires, EPSTEIN fully intends to testify to all relevant and nonobjectionable inquiries made to him in discovery be it a deposition, in interrogatories or in production requests. (Emphasis Added) However, the current circumstances are such that by testifying or responding to discovery, EPSTEIN will be required to waive his constitutional privileges, thereby subjecting himself to criminal prosecution and scrutiny by the USAO as a
+
+Page 5
+
+result of matters alleged in this civil action (and others before this Court and in the State of Florida 15th Judicial Circuit Court, Palm Beach County).
+
+The special circumstances of this action are such that a stay or continuance for a time certain is NOT prejudicial and is required to be entered so that:
+
+(1) EPSTEIN is not required to waive his Fifth Amendment right against selfincrimination under the United States Constitution resulting in severe prejudice to EPSTEIN in pending criminal matters; and
+
+(2) EPSTEIN is not forced to choose between waiving his Fifth Amendment right against self-incrimination or losing the civil case.
+
+Here, in asserting his Fifth Amendment Privilege, the Plaintiff is afforded an opportunity rarely given - that is, to put on only her evidence without any counterevidence from Defendant resulting in ajudgment of liability against EPSTEIN. This is inherently unfair and precisely the special circumstances where "in the interests of justice" a stay is required. Ventura v. Brosky, <sup>2006</sup>WL 3392207 (S.D. Fla. 2006), citing United States v. Lot 5, Fox Grove, <sup>23</sup>F.3d 359 (11th Cir. 1994). In Ventura, <sup>a</sup>stay was entered where a Defendant was confronted with issue of waiving his 5th Amendment Privilege or to loose a civil case by way of motion for summary judgment. Id. Here, EPSTEIN is not requesting a mandatory stay. EPSTEIN only asks that this court recognize that "special circumstances" exists in this matter and enter a stay in the "interests of justice" and only for a specified period of time (i.e., after the NPA expires). See al.22 Securities and Exchange Commission, <sup>755</sup>F.Supp. 1018, 1019 (S.D. Fla. 1990)(Defendant was in precarious position while being subject to criminal investigation and reasoning that compelling Defendant to speak by ordering an accounting of alleged illicit funds would directly
+
+Page 6
+
+impinge his right against self-incrimination). The court found it appropriate to grant the request for stay. (Emphasis Added).
+
+Citing to U.S. v. Lot 5, Fox Grove supra, the Southern District Court, Florida, in Ventura v. Brosky 2006 WL 3392207 (S.D. Fla. 2006), stated —
+
+The Eleventh Circuit has also created a test for these circumstances, stating that where there exists a concurrent civil and criminal proceeding, a court must stay a civil proceeding pending resolution of a related criminal prosecution when "special circumstances" so require in the "interests of justice."
+
+(Bold emphasis added). au also United States v. Kordel, 397 U.S. I, 12 & n. 27, 90 S.Ct. 763, 769-70 & n.27 (1970). The Ventura Court went on to state that "situations where a defendant in both criminal and civil proceedings must choose whether to waive his privilege against selfincrimination or to lose the civil case in summary or default judgment proceedings have met this test's burden and warrant a stay." Id. The Ventura court granted the stay. Here, the 15'h Judicial Circuit action lives along with the NPA.
+
+In making a decision to enter such a stay, the court may consider the following factors:
+
+- (I) the interests of the Plaintiffs in proceeding expeditiously with litigation, or any aspect of it, and the potential prejudice of Plaintiff to the delay;
+- (2) the burden which any particular aspect of the proceedings may impose on the defendant;
+- (3) the convenience of the court in the management of its cases, and the efficient use of judicial resources;
+  - (4) the interests of persons not parties to the civil litigation; and
+  - (5) the interest of the public in the pending civil and criminal litigation.
+
+Page 7
+
+See U.S. v. Pinnacle Ouest International, 2008 WL 4274498 (N.D. Fla. 2008).
+
+First, in applying the above factors, the Plaintiff in the instant matter will not be prejudiced simply by claiming a delay in time. Second, the burden is far greater on the EPSTEIN if he is forced to waive his 56 Amendment Privilege or remain silent and have a judgment entered against him or choose to testify and face criminal prosecution. Third, efficient use of judicial resources would be rendered upon a stay by way of preventing an appeal if such a stay is not entered. The Court has broad discretion to enter such a stay. Fourth, the interests of the individuals outlined in the NPA will be served because EPSTEIN's fulfillment of NPA alleged obligations is determinative upon whether the USAO prosecutes those individuals or whether the claims will be dropped upon the expiration of the NPA. Finally, the interest of the public in the pending civil and criminal cases will not be prejudiced as EPSTEIN is already serving his term whereby a plea was entered in the 15 Judicial Circuit action.
+
+# a. Application of the 5th Amendment
+
+Next, the Fifth Amendment privilege against self-incrimination "permits a person not to answer official questions put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), citin Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is also available to those who claim innocence. One of the Fifth Amendment's "basic functions ... is to protect innocent men ... 'who otherwise might be ensnared by ambiguous circumstances."); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process
+
+Clause of the Fourteenth Amendment - "(ilt would be incongruous to have different standards determine the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court."); Kastigar v. U.S., 406 U.S. 441, 444-45, 92 S.Ct. 1653 (1972XThe Fifth Amendment privilege "can be asserted in any proceeding, civil or criminal, administrative or judicial, investigatory or adjudicatory; and it protects against any disclosures which the witness reasonably believes could be used in a criminal prosecution or could lead to other evidence that might be so used. This Court has been zealous to safeguard the values which underlie the privilege." (Emphasis added)).
+
+The United States Supreme Court made it clear that the scope of the Fifth Amendment Privilege includes the circumstances as here "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see 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. Conboy, 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 tiring Blau v. United States 1950, 340 U.S. 159, 71 S.Ct. 223. The Fifth Amendment privilege against self-incrimination "permits a person not to answer official questions put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d at 669, citing Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). As EPSTEIN is here, "the claimant must be 'confronted by substantial and `real,' and not merely
+
+trifling or imaginary, hazards of incrimination."' See generally United States v. Apfelbatun, 445 U.S. 115, 128, 100 S.Ct. 948, 956, 63 L.Ed.2d 250 (1980)). See also, United States v. Neff, 615 F.2d 1235, 1239 (9th Cir.), cert. denied, 447 U.S. 925, 100 S.Ct. 3018, 65 L.Ed.2d 1117 (1980)(Information 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
+
+Page 11
+
+(concurring opinions). See Braswell v. United States. f487 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. 846 F.2d 678, 690 (11th Cir. I988)("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 10`h 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.MI, 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 jvhQsearcvlaw.com Co-Counsel for Plaintiff
+
+Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 Wcst 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 brucereinhartlaw. Couns• fo 'efendant
+
+Hee'
+
+Florida = ar No. 224 rcrit@belclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpike(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)
+
+<sup>A</sup>TRUE BILL /IC' er
+
+a," 2\_ IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA 7.;
+
+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.
+
+<sup>I</sup>hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law.
+
+//- Assistant State- At( frity of thia— Fifteenth Judicial Circuit of the State of Florida, prosecuting for the said State
+
+3RAND JURY FOREPERSON )ATE
+
+'effrey E. Epstein, Race: , Sex: Male, DOB: January 20, 1953, SS#: 090-44.3348; Issue Warrant
+
+EXHIBIT
+
+**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 "B"
+
+5. The criminal matters against EPSTEIN remain ongoing until the NPA expires by its terms in late 2010, and as long as the USAO determines EPSTEIN has complied with those terms and conditions. The threat of criminal prosecution against EPSTEIN by USAO in the Southern District of Florida continues presently and through late 2010.
+
+6. Pursuant to the terms of the NPA, the USAO possesses the right to declare that the agreement has been breached, give EPSTEIN's counsel notice, and attempt to move forward with a prosecution. As of the date of this Affidavit, the USAO has taken the position on a number of occasions that it might consider the following actions by EPSTEIN to be a breach of the NPA.
+
+- Investigation by EPSTEIN (by and through his attorneys) of this Plaintiff and the other Plaintiffs in other pending civil cases for purposes of defending the civil actions;
+- EPSTEIN's contesting damages in this action and other civil actions.
+- EPSTEIN or his legal representatives making statements to the press about this Plaintiff or the other Plaintiffs.
+- Using the word "jail" instead of "imprisonment" in the plea agreement with the Palm Beach County State Attorney's Office.
+
+7. EPSTEIN, through counsel, submitted a Freedom of Information Act request to the Federal Bureau of Investigation (FBI) for documents relating to this and the other cases; the FBI denied the request stating the materials are at this time exempt from disclosure because they are in an investigative file, i.e. the matter is still an ongoing criminal investigation.
+
+8. The NPA expires in late 2010.
+
+FURTHER THE AFFIANT SAYETH NAUGHT
+
+![]()STATE OF FLORIDA  
+COUNTY OF PALM BEACH
+
+I hereby Certify that on this day, before me, an officer duly authorized to administer oaths and take acknowledgments, personally appeared Jack A. Goldberger, Esquire, known to me to be the person described in and who executed the foregoing Affidavit, who acknowledged before me that he/she executed the same, that I relied upon the following form of identification of the above named person: Known Personally, and that an oath was/was not taken.
+
+WITNESS my hand and official seal in the County and State last aforesaid this 19<sup>th</sup> day of February, 2009.
+
+(SEARCHED
+
+![](_page_18_Picture_19.jpeg)
+
+![]()
+
+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CV-80811-MARRA/
+
+C.M. A.,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN and
+
+Defendants,
+
+## DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION
+
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, hereby responds to Plaintiffs First Request For Production To Defendant, served January 8, 2009 and states:
+
+Request No. 1: Any and all evidence required to be maintained by Epstein and the United States Attorney for the Southern District of Florida, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued in connection with the investigation referenced in the Non-Prosecution Agreement, and including certain computer equipment.
+
+Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this
+
+EXHIBIT
+
+\_.\6' , '.\s' <sup>r</sup>(ha,
+
+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
+
+jphOsearcylaw.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
+
+moike(d)bciclaw.com
+
+BURMAN, CRITTON, LUTTIER & COLEMAN
+
+515 N. Flagler Drive, Suite 400
+
+West Palm Beach, FL 33401
+
+561/842-2820 Phone
+
+561/515-3148 Fax
+
+(Counsel for Defendant Jeffrey Epstein)

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marker2/court-doe-v-epstein-80469/EFTA02750405/EFTA02750405.md

@@ -0,0 +1,137 @@
+## 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.: 013-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.: 08-80811-CIV-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08- 80893-CIV-MARRA/
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+DOE II, CASE NO.: 09- 80469-CIV-MARRA/
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN et al,
+
+Defendants.
+
+JANE DOE NO. 101, CASE NO.: 09- 80591-CTV-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 102 CASE NO.: 09- 80656-CIV-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## ORDER REQUESTING THE UNITED STATES TO PROVIDE ITS POSITION REGARDING DEFENDANT EPSTEIN'S MOTION TO STAY/CONTINUE THE CIVIL CASES PENDING AGAINST HIM
+
+THIS CAUSE is before the Court upon the motions filed in several cases by Defendant
+
+Jeffrey Epstein to Stay and/or Continue the Action for Time Certain Based on Parallel Civil and Criminal Proceedings. See, e.g., docket entry 51 in C.M.A. v. Epstein and =, case no. 08- 80811 (attached). Epstein moves for a stay until the expiration of the Non-Prosecution Agreement ("NPA") with the United States Attorney's Office (USAO) because, he claims, the USAO has taken the position that he is violating the NPA by defending the civil actions filed against him. Therefore, he argues that he cannot defend the civil actions without subjecting himself to criminal prosecution.
+
+While the Court recognizes that the United States is not a party to these actions and is not obligated to comment on this matter, the position of the United States would greatly assist the Court in resolving the merits of these motions to continue/stay the case. Accordingly, the Court requests that the United States provide its position on the matter. The Court would appreciate the governments position within 15 days if possible. If the United States is unwilling to state its position, the Court would also appreciate being so advised.
+
+DONE AND ORDERED in at West Palm Beach, Palm Beach County, Florida, this 14th day of May, 2009
+
+> KENNETH A. MARRA United States District Judge
+
+Copies furnished to: all counsel of record Ann Villafana

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marker2/court-doe-v-epstein-80469/EFTA02750409/EFTA02750409.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE II )CASE NO.: 09-80469-CIV-MARRA Plaintiff, ) ) ) VS. ) ) JEFFREY EPSTEIN. ) and ) ) Defendants. )
+
+## PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO SERVE REPLY TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS
+
+Plaintiff, JANE DOE II, respectfully requests an enlargement of time to serve her Reply to Defendant, JEFFREY EPSTEIN'S, Motion to Dismiss, and would show in support:
+
+- 1. The Reply to Defendant, JEFFREY EPSTEIN'S, Motion to Dismiss is due May 15, 2009. Due to the press of other business, Plaintiff's counsel has been unable to finish the reply to said motion which raises many complex issues that are typically not addressed on a motion to dismiss.
+- 2. Counsel certifies that he has today consulted with Robert Critton, Esq., Counsel for Jeffrey Epstein, and he does not oppose an enlargement of time until Friday May 22, 2009, for Plaintiff to serve her Reply to Defendant, JEFFREY EPSTEIN'S, Motion to Dismiss.
+
+WHEREFORE, Plaintiff respectfully requests that the Court grant an extension to serve the Reply to Defendant, JEFFREY EPSTEIN'S, Motion to Dismiss up to and including May 22, 2009.
+
+Respectfully submitted,
+
+BY: s/ Isidro M. ISIDRO M. Florida Bar No. 437883 LAW FIRM, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 Telephone:(561) 832-7732 Telecopier: (561) 832-7137 e-mail: isidrogarcia@bellsouth.net
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN CRITTON LUTTIER & COLEMAN, 515 N. Drive, Suite 400, West Palm Beach, Florida 33401 this 15th day of May, 2009.
+
+> BY:s/ Isidro M. ISIDRO M.

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marker2/court-doe-v-epstein-80469/EFTA02750411/EFTA02750411.md

@@ -0,0 +1,199 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 3
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 4
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80119-MARRA,
+
+CASE NO.: 08-CV-80232-MARRA
+
+CASE NO.: 08-CV-80380-MARRA I
+
+CASE NO.: 08-CV-80381-MARRA
+
+JANE DOE NO. 6
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 7
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+C.M.A.
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80994-MARRA
+
+CASE NO.: 08-CV-80993-MARRA/
+
+CASE NO.: 08-CV-80811-MARRA/
+
+CASE NO.: 08-CV-80893-IVIARRA
+
+DOE II
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 101
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 102
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 09-CV-80469-MARRA/M=
+
+CASE NO.: 09-CV-80591-MARRA/
+
+CASE NO.: 09-CV-80656-MARRA/
+
+PLAINTIFF'S NOTICE OF FILING WITHDRAWAL OF PREVIOUSLY RAISED OBJECTIONS TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO COMPEL AND/OR IDENTIFY C.M.A. IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY C.M.A. IN THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY, OR, ALTERNATIVELY, MOTION TO DISMISS SUA SPONTE, WITH INCORPORATED MEMORANDUM OF LAW
+
+Plaintiff, C.M.A., by and through her undersigned attorneys, hereby files notice of withdrawal of previously raised objections to Defendant, JEFRREY EPSTEIN'S, Motion
+
+to Compel and/or Identify C.M.A. in the Style of This Case and Motion to Identify C.M.A. in Third-Party Subpoenas For Purposes of Discovery, or, Alternatively, Motion to Dismiss Sua Sponte, With Incorporated Memorandum of Law, and further states as follows:
+
+1. Defendant, JEFFREY EPSTEIN, filed a Motion to Compel and/or Identify C.M.A. in the Style of This Case and Motion to Identify C.M.A. in Third-Party Subpoenas For Purposes of Discovery, or, Alternatively, Motion to Dismiss Sua Sponte, With Incorporated Memorandum of Law (D.E. 67) on April 29, 2009.
+
+2. EPSTEIN's Motion seeks the following relief (taken verbatim from the conclusion of his Motion):
+
+- a) "That C.M.A. be identified by her legal name in the style of this case;
+- b) That Epstein be granted leave to identify C.M.A. by her legal name in Third-Party Subpoenas (but not file them in Court, or, if required, in a redacted form); and
+- c) That on an alternative basis, this court dismiss this action Sua Sponte until such time as C.M.A. identifies herself in the style of this matter.
+
+Doe v. Rostker 89 F.R.D at 163."
+
+3. Plaintiff withdraws her objection to a) and b) requested above. The request to have C.M.A.'s case dismissed is rendered moot given C.M.A.'s acquiescence to a) and b). To the extent that it is not, however, C.M.A. continues to object to c) above.
+
+4. Counsel for EPSTEIN is free to prepare a proposed agreed order reflecting the above for the Court's consideration following the undersigned's review of same.
+
+## CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
+
+Counsel for the movant conferred via telephone with counsel for the Defendant regarding the filing of the instance Notice and he has no objection to Plaintiff filing same.
+
+s/ Jack P.
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that on the 20th day of May, 2009, I electronically filed the foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice of electronic filing to all counsel of record on the attached service list.
+
+> Is/.lank P ■ Jack Scarola Florida Bar No.: 169440 Jack P. Florida El No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9424 Attorneys for Plaintiff, C.M.A.
+
+**COUNSEL LIST**
+
+Richard H. Willits, Esquire
+
+Richard H. Willits, P.A.
+
+2290 10th Avenue North, Suite 404
+
+Lake Worth, FL 33461
+
+Phone: (561) 582-7600
+
+Fax: (561) 588-8819
+
+Robert Critton, Esquire
+
+Burman Critton Luttier & Coleman LLP
+
+515 North Flagler Drive, Suite 400
+
+West Palm Beach, FL 33414
+
+Phone: (561) 842-2820
+
+Fax: (561) 844-6929
+
+Jack A. Goldberger, Esquire
+
+Atterbury, Goldberger & Weiss, P.A.
+
+250 Australian Avenue South
+
+West Palm Beach, FL 33401
+
+Phone: (561) 863-9100
+
+Bruce E. Reinhart, Esquire
+
+Bruce E. Reinhart, P.A.
+
+250 South Australian Avenue
+
+Suite 1400
+
+West Palm Beach, FL 33401
+
+Phone: (561) 202-6360
+
+Fax: (561) 828-0983

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marker2/court-doe-v-epstein-80469/EFTA02750417/EFTA02750417.md

@@ -0,0 +1,61 @@
+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE II Plaintiff, vs. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA
+
+## PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS
+
+Plaintiff, JANE DOE II, through counsel, opposes Defendant's RICHARD EPSTEIN's Motion to Dismiss. Defendant's argument for a dismissal is premised on the following: 1) Plaintiff is not permitted to file a claim under Florida law in a State of Florida court and then file a federal claim in a federal court; 2) the remedies amendment to 18 U.S.C.§2255 are not retroactive based on the dates Defendant EPSTEIN is alleged to have violated the statute; 3) damages under §2255 cannot be obtained on a per incident basis, but must be lumped together into a single recovery despite multiple violations occurring in temporally distinct time frames, and therefore being different incidents; 4) Plaintiff has failed to state a cause of action under §2255 because she has failed to "allege facts constituting a predicate act"; and 5) Plaintiff has failed to state a cause of action for conspiracy to violate §2255.
+
+## I. LEGAL STANDARD
+
+Defendant's motion to dismiss must be denied unless it appears beyond doubt that the plaintiff can prove no set of facts in support of her claims that would entitle her to relief.
+
+Conley v , 355 U.S. 41, 45-46 (1957). The Court must accept all of plaintiff's factual allegations as true. Schuer v. 416 U.S. 232 (1974). Rule 8(a)(2) of the Federal Rules of Civil Procedure provides that a complaint need only be "a short and plain statement of the claim," and as long as the pleadings "give defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests," notice pleading has been satisfied. Conley v. 355 U.S. at 47. For a claim to state a cause of action however, facts, not labels and conclusions must be asserted. Bell Atl. Corp. v. Twombly 550 U.S. 544 (2007)
+
+## II. ARGUMENT
+
+Point 1. Plaintiff has every right to proceed in State court for a Florida common law claim, and in this Court for a federal claim.
+
+Defendant EPSTEIN's argument on this point is frivolous. Plaintiffs claims in State court are based on the common law of Florida, while the federal claims are based on a federal statutory remedy.' There are different facts that prove each claim and different elements to the claims. Defendant seems to be arguing that the Plaintiff forfeits a right to a federal remedy when she invokes a parallel, but independent and wholly distinct right to a State remedy. That is simply not supported by any case or reasonable interpretation of any case. The lynchpin of Defendant's argument is that concurrent jurisdiction is available to hear all claims in one forum; that is simply not the case, since the state claims are vastly different than the federal statutory remedy. If the State claims had been filed in this Court, this Court would not be obligated to exercise concurrent jurisdiction. It is well established that the exercise of supplemental jurisdiction is discretionary with the court, and is properly rejected
+
+On a Motion to Dismiss, the Court is of course confined to the four corners of the Complaint, and it is completely improper for the Defendant to attach as Exhibits copies of a Complaint from a different proceeding, a fact that is not alleged anywhere in the Complaint at issue before this Court. Nevertheless because the Defendant's argument on this issue is meritless, Plaintiff addresses it on the merits.
+
+under many circumstances.2
+
+28 U.S.C. §1367, "supplemental jurisdiction," provides that:
+
+©) The district courts may decline to exercise supplemental jurisdiction over a claim under subsection (a) if--
+
+(1) the claim raises a novel or complex issue of State law,
+
+(2) the claim substantially predominates over the claim or claims over which the district court has original jurisdiction,
+
+(3) the district court has dismissed all claims over which it has original jurisdiction, or
+
+(4) in exceptional circumstances, there are other compelling reasons for declining jurisdiction.
+
+Courts routinely "are obligated to raise and decide issues of subject matterjurisdiction sua sponte any time it appears subject matter jurisdiction is absent." Carias v. Lenox Financial Mortgage Corporation 2008 U.S. DIST. LEXIS 20345 \*1 (N.D. Cal. March 5, 2008). In Carias, after granting summary judgment on the sole federal claim, the Court remanded the State claims to state court, stating: 'The Court declines to exercise pendent jurisdiction over the state law claims and remands the action to state court. The Court finds that the issues of economy, convenience, fairness and comity collectively weigh in favor of remand. See Harrell 934 F.2d at 205. Comity weighs especially strong, given that the remaining claims are pure state law claims with no connection to federal law. Economy also weighs in favor of remand as state courts are better equipped to efficiently handle state
+
+In United Mine Workers v. Gibbs 383 U.S. 715 (1966), a jury's verdict against a union based on State law claims was reversed, in part, because the federal law claim failed. The Court noted that: "It has consistently been recognized that pendent jurisdiction is a doctrine of discretion, not of plaintiff's right. Its justification lies in considerations of judicial economy, convenience and fairness to litigants; if these are not present a federal court should hesitate to exercise jurisdiction over state claims, even though bound to apply state law to them, Erie R. Co. v. Tompkins 304 U.S. 64.Needless decisions of state law [by a federal court] should be avoided both as a matter of comity and to promote justice between the parties, by procuring for them a surer-footed reading of applicable law."
+
+law claims." Id. at \*5-6 (emphasis added). In Daimler Chrysler Corporation v. Charlotte Cuno, 547 U.S. 332, 351-52 (2006) the Supreme Court stated:
+
+Gibbs held that federal-question jurisdiction over a claim may authorize a federal court to exercise jurisdiction over state-law claims that may be viewed as part of the same case because they "derive from a common nucleus of operative fact" as the federal claim. 383 U.S., at 725, 86 S. Ct. 1130, 16 L. Ed. 2d 218. Plaintiffs assume that Gibbs stands for the proposition that federal jurisdiction extends to all claims sufficiently related to a claim within Article III to be part of the same case, regardless of the nature of the deficiency that would keep the former claims out of federal court if presented on their own.
+
+Our general approach to the application of Gibbs, however, has been markedly more cautious. For example, as a matter of statutory construction of the pertinent jurisdictional provisions, we refused to extend Gibbs to allow claims to be asserted against nondiverse parties when jurisdiction was based on diversity, see Owen Equipment & Erection Co. v. Kroger, 437 U.S. 365, 98 S. Ct. 2396, 57 L. Ed. 2d 274 (1978), and we refused to extend Gibbs to authorize supplemental jurisdiction over claims that do not satisfy statutory amount-in-controversy requirements, see Finley v. United States, 490 U.S. 545, 109 S. Ct. 2003, 104 L. Ed. 2d 593 (1989). As the Court explained just last Term, "we have not . . . applied Gibbs' expansive interpretive approach to other aspects of the jurisdictional statutes." Exxon Mobil Corp. v. Allapattah Servs., 545 U.S. 546, 553, 125 S. Ct. 2611, 162 L. Ed. 2d 502 (2005) (applying 28 U.S.C. § 1367, enacted in 1990, to allow a federal court in a diversity action to exercise supplemental jurisdiction over additional diverse plaintiffs whose claims failed to meet the amount-in-controversy threshold).
+
+***What we have never done is apply the rationale of Gibbs to permit a federal court to exercise supplemental jurisdiction over a claim that does not itself satisfy those elements of the Article III inquiry***, such as constitutional standing, that "serve to identify those disputes which are appropriately resolved through the judicial process." Whitmore, 495 U.S., at 155, 158, 110 S. Ct. 1717, 109 L. Ed. 2d 135.
+
+(Emphasis added)
+
+Defendant's argument that the Court should abstain from deciding the purely federal issues in this case because there is an independent action under State law is absurd. For this argument the Defendant relies on the Colorado River abstention doctrine, clearly
+
+inapplicable to this case. Only in "exceptional" circumstances, to promote conservation of judicial resources and comprehensive disposition of litigation, would a federal court be authorized to dismiss federal parallel' claims that are initiated in state court. Colorado River Water Conservation District v. United States, 424 U.S. 800 (1976). However, for the Colorado River doctrine to even apply, there must be clear Congressional direction that would preclude a federal court's "virtually unflagging obligation ...to exercise federal jurisdiction." Id. at 817. In that case, the Supreme Court found that clear Congressional direction from the McCarran Amendment, which the Court read to counsel against "piecemeal litigation" concerning issues of water rights in a river system, favored abstention It at 819. Even with this clear Congressional direction, if other factors had not favored abstention, it may not have been ordered. Ids at 820.
+
+Defendant EPSTEIN does not offer any evidence of any Congressional direction that would direct this Court to abstain for claims under 18 U.S.C. §2255.4 Further, the Colorado River doctrine only applies when federal courts are presented with "difficult questions of state
+
+<sup>&#</sup>x27;The federal claims that are the subject matter of this action are not necessarily parallel, although the incidents that gave rise to both the federal and state claims arise from the same series of events. A Florida appellate court, for example, has refused to apply principles of res judicata to bar State discrimination claims after the plaintiff lost federal discrimination claims. IIIIII v. National Property & Casualty Underwriters 659 So. 2d 1214 (Fla. 4th DCA 1995) (adverse judgment against plaintiff in federal court for federal discrimination claims did not bar subsequent action under state discrimination laws). Here, although some of the elements for some of the claims may be similar, they are sufficiently different that application of would preclude res judicata. To determine whether a case is parallel, courts have looked to whether the same issues are being litigated. Calvert Fire Ins. Co. v. American Mut. Reins. Co., 600 F.2d 1228, 1229, n. 1 (7th Cir. 1979); the issues in the State court and in this Court are not the same.
+
+<sup>&#</sup>x27;The Supreme Court said that Congressional direction is the &quot;[m]ost important factor.&quot; Id. at 819.</p><p block-type='Text'>law bearing on policy problems of substantial public import whose importance transcends the result in the case at bar.&quot; dI . at 814 (emphasis added).5 Plaintiff in this case is not asking this Court to adjudicate any claims under State law, nor do the claims presented &quot;policy problems of substantial public import.&quot; This case involves claims against an individual brought by another individual.</p><p block-type='Text'>Just how narrow the circumstances under which abstention is appropriate under the Colorado River doctrine, was demonstrated in the subsequent decision of the Supreme Court in the case of Will v. Calvert Fire Insurance Co. 437 U.S. 655 (1979). In Will the Supreme Court further narrowed the contours of when a federal court may abstain when there is a parallel state action. In that case, a bare majority of one held upheld the District Court&#x27;s decision to abstain, however, Justice Blackmun, in casting the deciding vote, did so because he was of the opinion that the remedy sought (mandamus) was premature, since the Appellate Court which had reversed the District Court, should have simply directed it to reconsider the issue in light of the very limited circumstances under which abstention is appropriate under the Colorado River doctrine. Id. at 668.</p><p block-type='Text'>While the Will case recognizes that Colorado River abstention is a matter generally left to the sound discretion of the District Court, the Eleventh Circuit has abolished its application for claims predicated on 42 U.S.C.§1983. Alacare. Inc. v.Bagiano 785 F. 2d 963 (11th Cir. 1986);See also: Tovar v. Billmeyer, 609 F. 2d 1291 (9th Cir. 1979) (rejecting application of abstention in Section 1983 cases). Defendant cites no cases where the</p><p>Colorado River has been applied where the plaintiff is pursuing federal civil rights claims in state and federal courts, at the same time, which is not the case here. See for example: Atchinson v. Nelson, 460 F. Supp. 1102 (D. Wyo. 1978).</p><p block-type='Text'>Colorado River doctrine has been applied to a federal claim under §2255. The cases cited by Defendant EPSTEIN do not support a decision by this Court to abstain over what is a purely federal claim. In American Bankers Ins. Co. v. First State Ins. Co. 891 F.2d 882 (11th Cir. 1990), the District Court dismissed a purely state law claim for equitable subrogation because there had been an earlier claim for declaratory relief in State Court; the Eleventh Circuit reversed, concluding</p><blockquote><p block-type='Text'>...that no exceptional circumstances require dismissal of this case in deference to the pending state court proceeding. If it were simply a question of judicial economy, this litigation probably should proceed in the New York court. A federal court cannot properly decline to exercise its statutory jurisdiction, however, simply because judicial economy might be served by deferring to a state court. Federal courts have a &#x27;virtually unflagging obligation&#x27; to exercise the jurisdiction given them.&#x27; Colorado River 424 U.S. at 816, 96 S. Ct. at 1246. The interest in preserving federal jurisdiction mandates that this action not be dismissed.</p></blockquote><p block-type='Text'>891 F.2d at 886.</p><p block-type='Text'>Finally, Plaintiff has pled that Defendant EPSTEIN has made an agreement with the United States Attorney&#x27;s Office to not contest the jurisdiction of this Court in exchange for a avoiding prosecution under federal law for solicitation of minors for prostitution. Complaint, ¶15. Defendant EPSTEIN appears to be violating the agreement in contesting the jurisdiction of this Court; at a minimum, at this stage of the pleadings he should be estopped from contesting jurisdiction, since the allegations of ¶15 must be accepted as true.6</p><p block-type='Text'>Point 2. The retroactivity of the amendments to §2255 is not appropriately addressed in a motion to dismiss; but if the Court is so inclined to consider it, there are insufficient facts pled in the Complaint to render the 2006 amendments inapplicable to the case at bar.</p><p>Plaintiff acknowledges that Defendant EPSTEIN&#x27;s agreement is between the United States and he; however, the Plaintiff and the other victims of his sexual predation may be considered third party beneficiaries to the agreement.</p><p block-type='Text'>The only issue properly before the Court is whether the Complaint states a cause of action. ¶14 of the Complaint claims that the Plaintiff is entitled to the sum of \$150,000 for each event wherein Defendant EPSTEIN solicited the Plaintiff for prostitution. Each event is set forth in the Complaint in ¶13.&#x27; There are two related issues before the Court: 1) the amount of minimum damages recoverable, \$50,000, or \$150,000; and, 2) whether the Plaintiff can recover the minimum amount of damages for each temporally distinct event, or whether she is restricted to a single recovery of the minimum damages recoverable under the statute.</p><p block-type='Text'>For the first issue, it is Plaintiff&#x27;s position that the matter cannot be decided on a motion to dismiss, because what Defendant EPSTEIN is asking the Court to do is to declare, prematurely, that when the Court instructs the jury, it instruct them that the minimum recovery for the Plaintiff, if she proves the allegations, is either \$50,000 (for the entire set of events, Defendant EPSTEIN&#x27;s position) or \$150,000 for each event (Plaintiff&#x27;s position); this issue cannot be settled on a motion to dismiss, but is better reserved for the charging conference at trial. On the second issue, as will be addressed later, under the plain language of the statute, since Defendant EPSTEIN can be criminally prosecuted for each temporally distinct event where he solicited this minor for prostitution, he can be subjected to the civil remedy for damages for each such event, under either version of the statute. This second</p><p>Plaintiff alleges that Defendant EPSTEIN, or others working on his behalf, solicited the Plaintiff for prostitution, while she was a minor, on &quot;6/16/03, 7/2/03, 4/9/04, 6/7/04, 7/30/04, 8/30/04, 10/9/04, 10/12/04, 10/30/04 and 11/9/04. In addition, Plaintiff believes that there were as many as 10 to 20 other occasions during this time frame that Defendant EPSTEIN solicited her and procured her to perform prostitution services, all during the time that she was a minor.&quot;</p><p block-type='Text'>issue would be better addressed on a summary judgment motion, and again, has nothing to do with whether Plaintiff has pled a cause of action pursuant to Rule 12(b)(6), Fed. R. Civ. P.</p><p block-type='Text'>Plaintiff agrees with the general proposition that a new law that creates new substantive rights, absent Congressional direction to the contrary, does not have retroactive effect, but this is not a new law. §2255 was amended in 2006, to, inter alia, provide an enhanced minimum recovery for damages caused by sexual predators such as Defendant EPSTEIN. However, the change in the civil remedies available of a statute is a procedural, not a substantive change in the law, and procedural changes to a statute are routinely applied retroactively.9 Where substantive changes in a law are made by Congress, a slim majority of the Supreme Court has declined retroactive application, even where the law was ostensibly enacted to overrule a Court precedent that had itself, in the view of Congress, overruled earlier Court precedents. Rivers v. Roadway Express 511 U.S. 298, 308 (1994).9</p><p><sup>-</sup>Defendant EPSTEIN also cites to United States v. Siegel 153 F.3d 1256 (11&#x27;9 Cir. 1998), wherein, based on a defendant&#x27;s inability to pay restitution mandated by a penal statute, the Court reversed a restitution order. An amendment to the statute removed from consideration the defendant&#x27;s ability to pay restitution; the Court said such an amendment could not be applied retroactively because the provision amounted to a punishment under a penal statute, and would violate the ex post facto provision in the U. S. Constitution, This case is clearly distinguished our case: the statute here is a civil, not a penal remedy; the amendment to the statute modifies the minimal exposure of the Defendant, but does not, as in the Siegel case, dispense with a substantive defense to a restitution claim. United States v. Whiting, 165 F.3d 631 (8&#x27;9 Cir. 1999), where a conviction for possession of child pornography was upheld, despite the fact that the conduct of the defendant was arguably not specifically proscribed by statute at the time the images were possessed; the Court held the legislative amendment was a mere clarification of the prior legislation and not an ex post facto law.</p><p>Justice Scalia cited the statement of purpose of the Civil Rights Act of 1991, to hold that, for example, the amendments specifically designed to overrule Patterson v. McLean Credit Union 491 U.S. 164, 105 L. Ed. 2d 132, 109 S. Ct. 2363, should be</p><p block-type='Text'>Similarly, in the companion case of Landgraf v. Usi Film Prods. 511 U.S. 244, 275, n. 28 (1994), the Court declined to retroactively apply substantive changes to Title VII cases, but noted that</p><blockquote><p block-type='Text'>While we have strictly construed the Ex Post Facto Clause to prohibit application of new statutes creating or increasing punishments after the fact, we have upheld intervening procedural changes even if application of the new rule operated to a defendant&#x27;s disadvantage in the particular case. See e. g. Dobbert v. Florida 432 U.S. 282, 293-294, 53 L. Ed. 2d 344, 97 S. Ct. 2290 (1977)• see also v. Youngblood 497 U.S. 37, 111 L. Ed. 2d 30, 110 S. Ct. 2715 (1990); Beazell v. Ohio 269 U.S. 167, 70 L. Ed. 216, 46 S. Ct. 68 (1925).</p></blockquote><p block-type='Text'>The question becomes then is an increase in the minimum guaranteed damages of a civil remedy statute a substantive or a procedural change? A careful reading of Landsgraf compels a finding that it is a procedural change only that must be given retroactive application. Although the Landsgraf Court declined to give retroactive application to the change most analogous to the one at issue here, it did so because it found the newly created right to compensatory damages, previously not available under Title VII, and made available by the Civil Rights Act of 1991, was in effect the creation of a new statute:</p><blockquote><p block-type='Text'>The provision of § 102(a)(1) authorizing the recovery of compensatory damages is not easily classified. It does not make unlawful conduct that was lawful when it occurred; as we have noted, supra, 511 U.S. at 252-255, § 102 only reaches discriminatory conduct already prohibited by Title VII. Concems about a lack of fair notice are further muted by the fact that such discrimination was in many cases (although not this one) already subject to monetary liability in the form of backpay. Nor could anyone seriously contend</p></blockquote><p block-type='Text'>applied prospectively only, based on a statutorily expressed Congressional intent to do so: &quot;The statute that was actually enacted in 1991 contains no comparable language. Instead of a reference to &#x27;restoring&#x27; pre-existing rights, its statement of purposes describes the Act&#x27;s function as &#x27;expanding the scope of relevant civil rights statutes in order to provide adequate protection to victims of discrimination.&#x27; 1991 Act, § 3(4), 105 Stat. 1071 (emphasis added).&quot;</p><p>that the compensatory damages provisions smack of a "retributive" or other suspect legislative purpose. Section 102 reflects Congress' desire to afford victims of discrimination more complete redress for violations of rules established more than a generation ago in the Civil Rights Act of 1964. At least with respect to its compensatory damages provisions, then, § 102 is not in a category in which objections to retroactive application on grounds of fairness have their greatest force.</p><p>Nonetheless, the new compensatory damages provision would operate "retrospectively" if it were applied to conduct occurring before November 21, 1991. Unlike certain other forms of relief, compensatory damages are quintessentially backward looking. Compensatory damages may be intended less to sanction wrongdoers than to make victims whole, but they do so by a mechanism that affects the liabilities of defendants. They do not "compensate" by distributing funds from the public coffers, but by requiring particular employers to pay for harms they caused. The introduction of a right to compensatory damages is also the type of legal change that would have an impact on private parties' planning. In this case, the event to which the new damages provision relates is the discriminatory conduct of respondents' agent John [REDACTED]; if applied here, that provision would attach an important new legal burden to that conduct. The new damages remedy in § 102, we conclude, is the kind of provision that does not apply to events antedating its enactment in the absence of clear congressional intent.</p><p><b><i>In cases like this one, in which prior law afforded no relief, § 102 can be seen as creating a new cause of action, and its impact on parties' rights is especially pronounced.</i></b> Section 102 confers a new right to monetary relief on persons like petitioner who were victims of a hostile work environment but were not constructively discharged, and the novel prospect of damages liability for their employers. Because Title VII previously authorized recovery of backpay in some cases, and because compensatory damages under § 102(a) are in addition to any backpay recoverable, the new provision also resembles a statute increasing the amount of damages available under a preestablished cause of action. Even under that view, however, the provision would, if applied in cases arising before the Act's effective date, undoubtedly impose on employers found liable a "new disability" in respect to past events. See <u>Society for Propagation of the Gospel</u>, 22 F. Cas. at 767. The extent of a party's liability, in the civil context as well as the criminal, is an important legal consequence that cannot be ignored. Neither in [REDACTED] itself, nor in any case before or since in which Congress had not clearly spoken, have we read a statute substantially increasing the monetary liability of a private party to apply to conduct occurring before the statute's enactment. See <u>Winfree v. Northern Pacific R. Co.</u>, 227 U.S. 296, 301, 57 L. Ed. 518, 33 S. Ct. 273 (1913) (statute creating new federal cause of action for wrongful death</p><p block-type='Text'>inapplicable to case arising before enactment in absence of &quot;explicit words&quot; or &quot;clear implication&quot;)• United States Fidelity &amp; Guaranty Co. v. United States ex rel. Struthers Wells Co. 209 U.S. 306, 314-315 (1908) (construing statute restricting subcontractors&#x27; rights to recover damages from prime contractors as prospective in absence of &quot;clear, strong and imperative&quot; language from Congress favoring retroactivity).</p><p block-type='Text'>Id. at 281-86 [footnotes omitted).</p><p block-type='Text'>Here, we have an increase in the potential damages remedy, but it was a damages remedy that already existed at the time of Defendant EPSTEIN&#x27;s commission of the acts against the minor. Hence, here, unlike Landsqraf, there was an existing civil remedy prior to Defendant EPSTEIN&#x27;s commission of the acts against the minor Plaintiff, and there continues to be such a remedy. Similar to our fact situation here, in v. School Bd. of Richmond 416 U.S. 696, 40 L. Ed. 2d 476, 94 S. Ct. 2006 (1974), a unanimous Court applied an intervening statute authorizing an award of attorney&#x27;s fees for parties seeking to end school segregation, to a case pending on appeal at the time the statute was enacted. Noting that the statute created an &quot;additional basis or source for the Board&#x27;s potential obligation to pay attorneys&#x27; fees,&quot; 416 U.S. at 721, the Court found that the statute&#x27;s retroactive application did not adversely affect the settled expectations of the parties. It is difficult to imagine, particularly when the Court is contemplating a motion to dismiss, that Defendant EPSTEIN had a &quot;settled expectation&quot; that if and when he was caught for solicitation of minors for prostitution he would be liable for only a minimum of \$50,000; it is highly probable that he never believed he would be caught and he never knew of or contemplated the civil penalties he would face under §2255. It is highly unlikely that Defendant EPSTEIN made those calculations when he committed the crimes against this or any other minor. Hence the rationale usually advanced for prospective application of</p><p block-type='Text'>statutory enactments is simply not present here, and the record is devoid of any factual material that would support such a conclusion.10 As Justice Blackmun said in dissent in Landsgraf, there is no vested right to break the law.&quot;</p><p block-type='Text'>Bottom line is, a motion to dismiss a claim is not the correct procedural mechanism to determine the retroactivity of a statute. Landsgraf was decided after a trial on the merits of the claim, wherein the trial court determined that although the sexual harassment was serious, the employer, upon learning of it, had taken prompt remedial measures to correct it, and the plaintiff did not have sufficient cause to warrant quitting her job. W. at 247-48. Rivers v. Roadway Express 511 U.S. 298 (1994) was decided after a trial on the merits as well, wherein the Court dismissed the 1981 claims based on the holding in Patterson supra and exonerated the Defendant on the Title VII claims in a bench trial. On appeal, the plaintiff sought relief under the 1991 Civil Rights Act amendments, which overruled Patterson. These</p><p>Although outside the pleadings and not appropriate for consideration on a Motion to Dismiss, Defendant EPSTEIN has refused to answer any substantive questions in the only two (2) depositions he has given in all these cases, including in the State court case involving this Plaintiff. Accordingly, Plaintiff has not been able to ascertain whether Defendant EPSTEIN had settled expectations about the limits of his civil liability under §2255.</p><p><sup>&</sup>quot;At no time within the last generation has an employer had a vested right to engage in or to permit xual harassment; &#x27;there is no such thing as a vested right to do wrong.&#x27; Freeborn v. , 69 U.S. 160, 2 Wall. 160, 175, 17 L. Ed. 922 (1865). See also 2 N. , Sutherland on Statutory Construction § 41.04, p. 349 (4th rev. ed. 1986) (procedural and remedial statutes that do not take away vested rights are presumed to apply to pending actions). Section 102 of the Act expands the remedies available for acts of intentional discrimination, but does not alter the scope of the employee&#x27;s basic right to be free from discrimination or the employers corresponding legal duty. There is nothing unjust about holding an employer responsible for injuries caused by conduct that has been illegal for almost 30 years.&quot; Id. at 297. Similarly in this case, soliciting minors for acts of prostitution, has been unlawful and the civil remedy associated therewith has long preceded the acts in question.</p><p block-type='Text'>cases where in a much different procedural posture than the present case, and the law that is applicable, including the raise of the minimum cap to \$150,000, was in place well before this suit was filed. Further, well before this suit was filed Defendant EPSTEIN entered into a deferred prosecution agreement wherein he agreed to not contest the jurisdiction of this Court and liability for claims under §2255, and Plaintiff has so alleged in ¶15 of the Complaint. Plaintiff did not allege that Defendant EPSTEIN made this agreement with a specification that his damages would be limited to a single claim of a minimum recovery under the former statute, which was amended in 2006.</p><h1>Point 3. 18 U.S.C. §2255 permits a claim for each temporally distinct event.</h1><p block-type='Text'>(a) In general. Any person who, while a minor, was a victim of a violation of section 2241©), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title [18 USCS § 2241©), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423] and who suffers personal injury as a result of such violation, regardless of whether the injury occurred while such person was a minor, may sue in any appropriate United States District Court and shall recover the actual damages such person sustains and the cost of the suit, including a reasonable attorney&#x27;s fee. Any person as described in the preceding sentence shall be deemed to have sustained damages of no less than \$ 150,000 in value.</p><p block-type='Text'>The statute makes reference to &quot;a violation&quot; and &quot;such violation,&quot; both references being in the singular. The statute does not say that if there are multiple violations, the Plaintiff is limited to a single recovery for all. Such a construction would to the plain language of the statute and common sense. Plaintiff has alleged that Defendant EPSTEIN violated the statute on 10 confirmed occasions and up to 20 additional occasions. Each date for each violation is different. There is no language in the statute that prohibits the Plaintiff from suing for each violation, and the dicta set forth in Tilton v. Playboy Entertainment Group, Inc. 554 F. 3d 1371 (11th Cir. 2009), vaguely noting that the District Court awarded the Plaintiff &quot;the</p><p block-type='Text'>minimum &#x27;actual damages- , Id. at 1379, but there is no suggestion in this Opinion that the Plaintiff was so limited, no reference to whether Plaintiff sought the relief being sought here or that the events she complained of occurred on multiple occasions. In fact, it appears clear from the Opinion that the pro se Defendant that Plaintiff prevailed against by default was sued for a singular violation of recording the Plaintiffs sexually oriented performance at a Spring Break gathering. There is no indication that the conduct that was recorded by the defaulted Defendant occurred on multiple occasions, as here.</p><p block-type='Text'>Point 4. The Eleventh Circuit has foreclosed Defendant EPSTEIN&#x27;s argument that for a violation of 18 U.S.C. 2422(b) to occur, he must travel in interstate commerce; moreover, he has waived his right to contest the jurisdiction of the Court according to the allegations of the Complaint.</p><p block-type='Text'>In United States v. Yost 479 F.3d 815 (11&#x27;&quot; Cir. 2007), a defendant was convicted of two counts of attempting to induce persons he believed were minors (they were government agents posing as minors) to commit acts of prostitution under 18 U.S.C. §2422(b); he sought to void his convictions on appeal because he didn&#x27;t get to the meeting place. The Court rejected the argument, holding:</p><blockquote><p block-type='Text' class='has-continuation'>We are not convinced by Yost&#x27;s argument that his failure to arrive at the meeting place precludes a finding of a substantial step. Although this is the first time we have been confronted with an attempt conviction under 18 U.S.C. § 2422(b) where travel is not involved, two other circuits have examined the issue and determin travel is not necessary to sustain such a conviction. In United States v. , 228 F.3d 637, 639-40 (6th Cir. 2000), the Sixth Circuit affirmed a conviction under Section 2422(b) where the defendant sent e-mails proposing oral sex and attempted to set up meetin s with minor females, albeit unsuccessfully. Similarly, in United States v. , 410 F.3d 1235, 1246 (10th Cir. 2005), the Tenth Circuit affirmed a Section 2422(b) attempt conviction, despite a lack of evidence of travel. The Tenth Circuit stated: crossed the line from &#x27;harmless banter to inducement the moment he began making arrangements to meet [the minor], notwithstanding the lack of evidence that he traveled to the supposed meeting place.&quot; Id. Viewing the</p></blockquote><p block-type='Text'>totality of Yost&#x27;s actions, we likewise conclude Yost crossed the line from mere ifie to inducement. In addition to his online chats with , Yost called on the telephone, posted pictures of his genitalia online, and made arrangements to meet her. Despite a lack of evidence of travel, the totality of Yost&#x27;s actions convinces us that a reasonable jury could have found Yost committed a substantial step.</p><p block-type='Text'>Id. at 820.</p><p block-type='Text'>As a practical matter, although not pled, the manner in which Defendant EPSTEIN solicited Plaintiff to commit acts of prostitution as alleged was by telephone, by use of one of his surrogate &quot;assistants,&quot; in this case Defendant .12 Plaintiff would receive a phone call on her cell phone (with a 561 exchange) from the cell phone of Defendant who used a cell phone with a New York exchange (917 area code). In United States v. Drury 396 F.3d 1303 (11th Cir. 2005), the Court had to determine whether a murder for hire conviction, where the defendant made calls from a Georgia land line to a federal agent posing as a hit man on a cell phone that routed calls through Jacksonville, was sufficient to establish use of interstate commerce for commission of the crime in question. The Court affirmed the conviction, even where there was no intent to use an instrumentality of interstate commerce, since the Defendant believed he was calling a number in Georgia.</p><p block-type='Text'>In this case, the facts will demonstrate that for 99 per cent of the solicitations for prostitution, Plaintiff was called by Defendant , who used her cell phone with a 917 exchange, a New York exchange, and presumably set up the event after being instructed by Defendant EPSTEIN when and at what time the Plaintiff should appear at his home for the</p><p>Ms. has been served in accordance with New York law after seeking to avoid service with the assistance of a doorman at her building. She has thus far failed to respond to the Complaint, and Plaintiff intends to move for a default against her next week.</p><p block-type='Text'>sexual services he paid the Plaintiff for. Defendant resides and is believed to have resided in New York at all times relevant to this suit, although she was present at Defendant EPSTEIN&#x27;s home on some of the occasions when the Plaintiff appeared after being summoned there. However, since she used a cellular phone, that is clearly a facility of interstate commerce as contemplated by 18 U.S.C. 2422(b), which encompasses conduct where &quot;any facility or means of interstate commerce&quot; is used.&quot; The Eleventh Circuit has recognized that &quot;ftlhe telephone system is clearly a &#x27;facility of interstate . . . commerce.&#x27;&quot; United States v. Covington 2009 U.S. App. LEXIS 8263 (111h Cir. April 22, 2009).</p><p block-type='Text'>Defendant EPSTEIN is alleged in the Complaint to have waived the right to contest the jurisdiction of this Court for claims under §2255, he should therefore be estopped from asserting the failure to allege predicate acts, particularly when he has refused to answer any questions based on his claimed right against self incrimination. However, if the Court is of the view that these predicate facts must be alleged despite the agreement, then Plaintiff requests leave to do so.</p><h2>Point 5. Plaintiff has pled sufficient facts to establish a conspiracy to violate §2255.</h2><p block-type='Text'>A civil conspiracy is an agreement by two or more persons, to do an unlawful act or a lawful act by unlawful means, the doing of an overt act in furtherance of the</p><p><sup>&</sup>quot;(b) Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall be fined under this title and imprisoned not less than 10 years or for life.&quot; (Emphasis added).</p><p>conspiracy, resulting in damage to the Plaintiff. <u>Walters v. Blankenship</u>, 931 So. 2d 137 (Fla. 5<sup>th</sup> DCA 2006); <u>Blatt v. [REDACTED]</u>, <u>Horn, et al.</u>, 456 So. 2d 949 (Fla. 3rd DCA 1984).</p><p>To support her claim of a civil conspiracy, Plaintiff has pled the following:</p><p>9. Defendant EPSTEIN, in agreement with two (2) persons he employed for this purpose, [REDACTED] and Defendant [REDACTED], conspired with these other two, and others, to solicit young women of the type Defendant EPSTEIN preferred, blonde, attractive in appearance, and younger than 18 years of age, to provide sexual gratification for him by engaging in acts of prostitution.</p><p>10. Defendants EPSTEIN and [REDACTED] entered into a criminal conspiracy to solicit young women for acts of prostitution, including the Plaintiff, here in Palm Beach County.</p><p>11. From about June, 2003 until on or about February, 2005, Defendants EPSTEIN and [REDACTED] persuaded, induced, or enticed the Plaintiff to come to Defendant EPSTEIN's home and provide Defendant EPSTEIN with "massages" which escalated into sexual encounters between Defendant EPSTEIN and the Plaintiff designed to fulfill his unnatural sexual desires for young women or even younger girls who were minors. These acts included Defendant EPSTEIN's request that he wanted the encounter to be like a "porn video." Defendant EPSTEIN would script lines for the Plaintiff to say, including calling out his name and requesting that he perform a certain sexual act "harder," while he touched the Plaintiff's vagina with a vibrator or with his fingers; alternately, he would masturbate in the presence of the Plaintiff after demanding her to disrobe and walk in front of him in provocative sexual poses. Defendant EPSTEIN would pay the Plaintiff a fee of \$200 on each occasion after he ejaculated while masturbating in the presence of the Plaintiff.</p><p>Plaintiff has pled the elements of a civil conspiracy to violate §2255.</p><h2>CONCLUSION</h2><p>Defendant's Motion to Dismiss must be denied. Plaintiff's Complaint states a cause of action pursuant to §2255. The <u>Colorado River</u> doctrine for abstention is not remotely applicable to this case, which is grounded on a purely federal statutory cause of action. It is</p><p block-type='Text'>inappropriate for the Defendant to seek to limit his minimum statutory exposure on a Motion to Dismiss, where there is no factual record or legislative history to determine the retroactivity of an enhanced damages provision to a cause of action that existed at the time of the wrongful acts. §2255 claims permit a Plaintiff to assert multiple claims for multiple violations that occur in temporally distinct time frames, no differently than any claim, whether based on tort or statutory law, that encompasses multiple events that occur at different times. Defendant EPSTEIN has waived the right to contest the issue of whether his conduct impacted interstate commerce; but Plaintiff is prepared to allege, if the Court deems it necessary, how his employee and co-conspirator, Defendant used an instrumentality of interstate commerce, her cell phone, to solicit the Plaintiff, then a minor, on behalf of Defendant EPSTEIN who solicited her sexual services for money. Finally, Plaintiff has pled all necessary elements to establish a civil conspiracy to violate §2255. For these reasons, Defendant EPSTEIN&#x27;s Motion to Dismiss must be denied; however, if the Court determines otherwise, Plaintiff respectfully requests leave to amend.</p><p block-type='Text'>Respectfully submitted,</p><p block-type='Text'>BY: s/ Isidro M. ISIDRO M. Florida Bar No. 437883 LAW FIRM, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 Telephone:(561) 832-7732 Telecopier: (561) 832-7137 e-mail: isidrogarcia@bellsouth.net</p><h2>CERTIFICATE OF SERVICE</h2><p block-type='Text'>I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN CRITTON LUTTIER &amp; COLEMAN, 515 N. Drive, Suite 400, West Palm Beach, Florida 33401 this 22nd day of May, 2009.</p><p block-type='Text'>ISIDRO M.</p>
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marker2/court-doe-v-epstein-80469/EFTA02750437/EFTA02750437.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.
+
+/
+
+C.M.A., CASE NO.: 08- CV-80811 -MARIZA/ I
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, et al.,
+
+Defendant.
+
+DOE II, CASE NO.: 08-CV- 80469-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN et al.,
+
+Defendant.
+
+CASE NO.: 08- CV-80893-MARRA,
+
+JANE DOE NO. 101, CASE NO.: 08- CV-80591-MARRA/JOHNSON
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant. /
+
+JANE DOE NO. 102, CASE NO.: 08- CV-80656-MARRAr
+
+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 11, 2009, to respond to the Defendant's Motions to Compel and/or Identify Jane Doe in the Style, a at.
+
+DONE AND ORDERED in NM, at West Palm Beach, Palm Beach County, Florida, this day of , 2009.
+
+DISTRICT COURT JUDGE

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marker2/court-doe-v-epstein-80469/EFTA02750440/EFTA02750440.md

@@ -0,0 +1,133 @@
+## 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-80381-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARR
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 7,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+C.M.A., CASE NO.: 08- CV-80811 -MARRA,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08- CV-80893-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN, 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-MARRia
+
+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. I 1 I filed in case no. 08-80119 on May 21, 2009.
+
+Dated: May 27, 2009 Respectfully submitted,
+
+By: si Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) ssm@sexabuseattorney.com Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattorney.com MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218
+
+Miami, Florida 33160
+
+Tel: (305) 931-2200
+
+Fax: (305) 931-0877
+
+## CERTIFICATE OF SERVICE
+
+I hereby certify that on May 27, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+/s/ Adam D. Horowitz
+
+## SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida
+
+Jack Alan Goldberger, Esq. igoldberger@agwpa.com
+
+Robert D. Critton, Esq. rcritton@bc1claw.com
+
+James bedwards@rra-law.com
+
+Isidro Manuel isidrogarcia@bellsouth.net
+
+Jack iah@searcvlaw.com Katherine Warthen Ezell KEzell@podhurst.com
+
+Michael James Pike MPike@bciclaw.com
+
+Paul G. Cassell cassellp@law.utah.edu
+
+Richard Horace Willits lawyerwillits@aol.com
+
+Robert C. Josefsberg rjosefsberg@podhurst.com
+
+/s/ Adam D. Horowitz

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marker2/court-doe-v-epstein-80469/EFTA02750446/EFTA02750446.md

@@ -0,0 +1,121 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+I
+
+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.
+
+CASE NO.: 09-CV-80469-MARRa
+
+JEFFREY EPSTEIN et al, Defendants.
+
+/
+
+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' NOTICE OF LIMITED APPEARANCE AS AMICUS CURIAE TO FILE RESPONSE TO COURT'S ORDER REOUESTING POSITION ON DEFENDANT'S MOTION TO STAY EDE 991
+
+Comes now the United States, by and through the undersigned Assistant United States Attorney, and makes this limited appearance to file via CM/ECF its response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. By filing this notice of limited appearance and its response, the United States does not make itself a party to this litigation and takes no position with respect
+
+to the outcome of any of the civil suits. By filing this notice of limited appearance and response, the United States also does not waive any procedural or statutory bars to suit.
+
+Respectfully submitted,
+
+R. ALEXANDER ACOSTA UNITED STATES ATTORNEY
+
+By: s/A. Villa aiia A. VILLAFANA Assistant United States Attorney Florida Bar No. 0018255 500 East Broward Boulevard, 7th Floor Ft. Lauderdale, FL 33394 Telephone: 954-356-7255 Facsimile: 954-356-7230
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that on May 28, 2009, 1 electronically filed the foregoing document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties are able to receive notice via the CM/ECF system.
+
+> s/A. Villa aiia A. VILLAFARA Assistant United States Attorney

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marker2/court-doe-v-epstein-80469/EFTA02750450/EFTA02750450.md

@@ -0,0 +1,145 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+I
+
+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.
+
+J
+
+C.M.A., Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+JANE DOE, Plaintiff,
+
+VS.
+
+JEFFREY EPSTEIN et al, Defendants.
+
+CASE NO.: 08-CV-8081I-MARRA/JOHNSON
+
+J
+
+CASE NO.: 08-CV-80893-MARRA
+
+DOE II, Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN et al, Defendants.
+
+CASE NO.: 09-CV-80469-MARRa
+
+JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARRA/JOHNSON
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+JANE DOE NO. 102 CASE NO.: 09-CV-80656-MARRA,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN, Defendant.
+
+#### UNITED STATES' RESPONSE TO COURT'S ORDER REQUESTING POSITION ON DEFENDANT'S MOTION TO STAY IDE 991
+
+Comes now the United States, by and through the undersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessary and was not contemplated by the Non-Prosecution Agreement between the United States and Defendant Jeffrey Epstein.
+
+### ISSUE PRESENTED
+
+The United States is not a party to these lawsuits and, accordingly, is not fully aware of the scope of the proceedings, the range of arguments presented by counsel, and any correspondence or oral communications between the parties in these civil suits. Based on the information presented by the Court and a review of Defendant Jeffrey Epstein's Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law (Court File No. 08-CV-80811- MARRA/JOHNSON DE 51-1), and responses thereto filed by various plaintiffs in their suits, the undersigned understands that the Court has requested the position of the United States on the following issue:
+
+Are there "special circumstances" that require the imposition of a stay of the civil proceedings in the "interests of justice" until the "expiration" of the Non-Prosecution Agreement ["NPA"] between the United States and Epstein?
+
+By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of any of the civil suits; nor does the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the NPA. The United States also declines to comment on Defendant Epstein's representations regarding past allegations of violations of the NPA by Epstein. The United States files this response solely as amicus curiae at the Court's request and does not waive any procedural or statutory bars to suit.
+
+# I. STANDARD FOR IMPOSING A DISCRETIONARY STAY
+
+#### A. The Defendant Must Show that the Assertion of His Fifth Amendment Privilege Against Self-Incrimination Would Automatically Result in the Entry of Summary Judgment Against Him.
+
+"The decision whether or not to stay civil litigation in deference to parallel criminal proceedings is discretionary.... A movant must carry a heavy burden to succeed in such an endeavor." Microfinancial, Inc. v. Premier Holidays Internal'!, Inc., 385 F.3d 72, 77 (1st Cir. 2004) (citations omitted). When a defendant facing possible criminal liability invokes his Fifth Amendment right against compelled self-incrimination in connection with civil litigation, a court can stay discovery or the entire civil case. v. Jenne, 2007 WL 624286 \*1 (S.D. Fl. Feb. 23, 2007) (Cooke, J.). "However, `the Constitution does not require a stay of civil proceedings pending the outcome of related criminal proceedings. Forcing an individual to risk non-criminal disadvantage by remaining silent for fear of self incrimination in a parallel criminal proceeding does not rise to the level of an unconstitutional infringement?" Id. (quoting Shell Oil Co. v. Altina Assocs., Inc., 866 F. Supp. 536, 540 (M.D. Fl. 1994)).
+
+As this Court has previously explained:
+
+The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United States v. Lot 5, Fox Grove, Alachua County, Fla, 23 F.3d 359, 363- 65 (11th Cir. 1994) ("Lot 5"), the Court articulated the following principles of law with respect to a stay of a civil action pending resolution of a related criminal action:
+
+[A] blanket assertion of the privilege is an inadequate basis for the issuance of a stay. Rather, a court must stay a civil
+
+proceeding pending resolution of a related criminal prosecution only when "special circumstances" so require in the "interests of justice." The court may deny a stay so long as the privilege's invocation does not compel an adverse judgment against the claimant.
+
+[T]he standard set by the Eleventh Circuit as to when a stay should be granted to prevent unconstitutional infringement is more narrow. The law in the Eleventh Circuit requires consideration of whether, as a result of invoking the privilege, the defendant faces certain loss of the civil proceeding on summary judgment if the civil proceeding were to continue. Lot 5, 23 F.3d at 364; Pervis v. State Farm Fire & Casualty Co., 901 F.2d 944 (1 1 th Cir. 1990). Under this standard, Movants must show that invocation of the privilege in the instant matter will result in certain loss by automatic summary judgment. United States v. Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most 'effective defense.' Securities & Exchange Comm. v. lncendy, 936 F. Supp. at 955 (S.D. H. 1996); Shell Oil Co., 866 F. Supp. at 540-41.
+
+Court-Appointed Receiver of Lancer Mgt. Group LLC v. Lauer, 2009 WL 800144 (S.D. Fl. Mar. 25, 2009) (Marra, J.).
+
+Thus, before reaching the relative benefit and prejudice to each of the parties caused by staying the cases, the Court must determine whether, if defendant Epstein were to invoke his Fifth Amendment right against self-incrimination' and the Court were to allow an adverse inference to be drawn therefrom, an adverse judgment against Epstein would be automatically compelled. The United States respectfully submits that it would not.
+
+<sup>&#</sup>x27;It appears from a brief review of some of Epstein's discovery responses that Epstein has made a blanket assertion of the privilege. For example, Epstein has asserted his Fifth Amendment privilege in response to a plaintiff's request to produce the NPA and the United States' list of identified victims although these documents were provided to Epstein by the United States.
+
+From a review of the Complaints filed by the plaintiffs in these cases, it appears that some have filed claims based upon Title 18, United States Code, Section 2255, some have filed claims based upon common law torts, and some have filed a combination of the two. Under general principles of tort law, a plaintiff is required to prove: (1) that the defendant committed a bad act; (2) that the plaintiff suffered damages; and (3) that the damages were caused by the defendant's bad act. To succeed on a claim under 18 U.S.C. § 2255, a plaintiff must show: (I) that the plaintiff is a person who, while a minor, was a victim of an enumerated offense committed by the defendant; (2) that the person suffered personal injury as a result of that violation; and (3) the amount of damages she sustained.
+
+Epstein's assertion of his Fifth Amendment privilege could result in the drawing of a negative inference only as to the first element under both of these claims. Therefore, to succeed on summary judgment (or at trial), the plaintiffs would still have to prove that they suffered personal injury/damages as a result of the defendant's bad act. Cf. In re Financial Federated Title & Trust, Inc., 252 B.R. 834, 838 (S.D. Fl. Bank. Ct. 2000) (Stay not warranted in bankruptcy proceeding where criminal indictment was pending because negative inference related only to defendant's receipt of allegedly fraudulent transfers, but "Trustee must still carry the burden of proving all of the elements of his complaint for fraudulent transfers . includ[ing] fraudulent intent, insolvency, and financial condition at the time of the transfers to the Defendants.").
+
+While Epstein may believe that his arguments and proof as to the first element are his "most effective defense," that alone is insufficient to warrant the imposition of a stay of the
+
+litigation. There are two other items for the Court to consider in deciding this issue. First, pursuant to the terms of the NPA, as to those victims identified by the United States, Epstein has already made a concession that they are victims of an enumerated offense committed by Epstein. Thus, this inference is drawn not due to his invocation of the right against selfincrimination but due to his entry into a contractual agreement with the United States for which the identified victims are third-party beneficiaries.' Second, in Lot 5, the Eleventh Circuit pointed out the wealth of evidence other than the defendant's testimony that could be used to defeat a liability claim. See Lot 5, 23 F.3d at 364 ("Thus, Claimant's assertion that only her own testimony could vindicate her is groundless; other participants to the illegal acts that gave rise to the forfeiture were available to testify at trial. Claimant's failure to indicate with precision why she did not use other parties' testimony to substantiate her defense was fatal."). For example, Epstein could mount a defense using effective cross-examination, telephone records, travel records, documents within the possession of the plaintiffs or third parties, and/or the testimony of third parties to rebut the plaintiffs' proof.
+
+<sup>&#</sup>x27;The United States notes that it is not aware of the identities of all of the plaintiffs in the civil suits. To the extent that any are not &quot;identified victims&quot; under the NPA, this contractual provision would not apply.</p><h1>B. Additional Factors to Consider in Balancing the Prejudice to the Parties</h1><p block-type='Text'>If the Court is persuaded that the negative inference drawn from Epstein&#x27;s assertion of his Fifth Amendment privilege would result in an automatic grant of summary judgment in favor of the plaintiffs, then the Court must engage in a balancing of equities in determining whether there are &quot;special circumstances&quot; warranting the imposition of a stay &quot;&#x27;to prevent a party from suffering substantial and irreparable prejudice.&quot; Securites and Exchange Comm&#x27;n v. Incendy, 936 F. Supp. 952, 956 (S.D. FL 1996) (quoting S.E.C. v. First Financial Group of Texas, Inc., 659 F.2d 660, 668 (5th Cir. 1981) (add&#x27;/ citations omitted).</p><p block-type='Text'>Examples of &quot;special circumstances&quot; provided by the Supreme Court in [United States v. Kordel] are: (1) if the Government brought the civil action solely to obtain evidence for its criminal prosecution, (2) if the Government failed to advise the defendant in the civil proceeding that it contemplates his criminal prosecution; (3) if the defendant is without counsel or reasonably fears prejudice from adverse pretrial publicity or other unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety.</p><p block-type='Text'>Incendy at 956 (citing United States v. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Comm&#x27;n v..261 Fed. Appx. 259, 263 (11th Cir. 2008) (&quot;[N]o &#x27;special circumstances&#x27; existed in this case warranting a stay, as there is no record evidence suggesting the Government had brought the civil case solely to obtain evidence for the criminal prosecution or that the criminal case against [defendant] was unconstitutional or inappropriately instituted.&quot;).</p><p block-type='Text' class='has-continuation'>No &quot;special circumstances&quot; exist here. First, unlike and Incendy, the United States Government is not a party to the civil litigation. Each suit is brought on behalf of an</p><p block-type='Text'>individual plaintiff represented by private counsel. Some of those plaintiffs are adverse to the United States and have filed suit against the Government based upon its handling of the criminal case against Epstein. (See In re Jane Doe Litigation, Court File No. 08-80736-Civ-Marra.) There has been no allegation, and certainly no showing, that the civil litigation is a ruse to obtain discovery on behalf of the criminal investigation.</p><p block-type='Text' class='has-continuation'>As some of the plaintiffs have mentioned, one purpose of the NPA was to place the identified victims in the same position where they would have been if Epstein had been convicted after trial of an offense enumerated in 18 U.S.C. § 2255. (See, e.g., Court File No. 08-CV-80119 DE 49-2.) If Epstein had proceeded to trial and been convicted, those victims would have been entitled to restitution and to file suit pursuant to 18 U.S.C. § 2255, and would have been entitled to the same sorts of discovery that they now seek. None of the plaintiffs has contacted the United States about passing on materials gathered through discovery to any criminal investigators or about seeking discovery that would be relevant only to the criminal proceedings, rather than to their individual cases. If Epstein has legitimate concerns that the civil discovery process is being abused in some way, he can ask the Court for a protective order limiting the scope of discovery or its distribution. Furthermore, if at some time in the future, Epstein were the subject of a criminal indictment and he alleged that the evidence to be used against him was gathered improperly, he could file a motion to suppress or to dismiss the indictment in that criminal action. See, e.g., United States, ex. rel. Westrick v. Second Chance, 2007 WL 1020808 \*4 (D.D.C. Mar. 31, 2007) (Defendant in civil False Claims Act suit moved to stay civil action pending criminal</p><p block-type='Text'>investigation where no indictment had been returned. The district court denied the motion, noting that while &quot;allowing civil discovery to proceed may afford the government [who was the real party in interest in the civil case] the opportunity to gain evidence that it may not be entitled to under the more restrictive criminal discovery rules, if and when discovery becomes necessary, protective orders and other remedial measures may be taken.&quot;) (citations omitted).</p><p block-type='Text'>By entering into the NPA, with its explicit discussion of 18 U.S.C. § 2255, Epstein acknowledged that the United States was trying to protect the victims&#x27; rights to restitution and that civil claims would likely follow. Epstein did not bargain for a stay of those proceedings. Instead, both parties received benefits and gave consideration for the bargain that was struck — while Epstein is faced with answering discovery requests that he would not face during criminal proceedings, he also is entitled to the identification of and extensive discovery from the victims, which he would not have received in the criminal case. Based upon a review of the discovery requests he has promulgated thus far, it appears that Epstein is taking full advantage of this benefit and if a criminal case were ever filed, he would, no doubt, seek to use that information in his defense.&#x27;</p><p><sup>&#</sup>x27;With respect to the other &quot;special circumstances&quot; mentioned in Incendy, the government obviously advised Epstein of the potential for criminal charges, and that knowledge led to the negotiation of the NPA. Epstein also has a number of attorneys listed on the Service List for the civil cases and has retained a similarly large number of attorneys to handle the criminal investigation and negotiation of the NPA. Epstein alleges a fear of adverse publicity, but as the plaintiffs have pointed out, during the course of the state and federal criminal investigations, Epstein&#x27;s personal publicist distributed stories to the press impugning the credibility of the victims and other witnesses and averring that the victims&#x27; allegations of abuse were made solely to extract money from the defendant. In the context of some of the civil suits currently pending, Epstein has asked the Court</p><p block-type='Text'>Unlike and Incendy, Epstein also has not been criminally indicted. In some districts, this alone is virtually dispositive. See, e.g., Sterling Nat&#x27;l Bank v. A-1 Hotels Interned?, 175 F. Supp. 2d 573, 576-77 (S.D.N.Y. 2001) (&quot;district courts in this Circuit `generally grant the extraordinary remedy of a stay only after the defendant seeking a stay has been indicted.&#x27;&quot; (quoting Citibank, N.A. v. 1993 WL 481335 \*1 (S.D.N.Y. Nov. 18, 1993) (add&#x27;/ citations omitted). As one court explained:</p><p block-type='Text'>the consensus that a party seeking a stay bears a heavier burden when he has not yet been indicted derives logically from the balancing test set out by the courts of appeals that have considered the question. When a defendant has been indicted, his situation is particularly dangerous, and takes a certain priority, for the risk to his liberty, the importance of safeguarding his constitutional rights, and even the strain on his resources and attention that makes defending satellite civil litigation particularly difficult, all weigh in favor of his interest. Moreover, if the potential prejudice to the defendant is particularly high post-indictment, the prejudice to the plaintiff of staying proceedings is somewhat reduced, since the criminal litigation has reached a crisis that will lead to a reasonably speedy resolution. Furthermore, at that stage in the criminal proceeding, the contours of the indictment will provide the Court with a reasonable basis for determining the extent of the threat to the defendant&#x27;s Fifth Amendment rights, and the likely extent and timing of the criminal litigation.</p><p block-type='Text'>Pre-indictment, these factors must be balanced significantly differently. Though many of the same risks to the civil defendant are present, the dangers are at least somewhat more remote, and it is inherently unclear to the Court just how much the unindicted defendant really has to fear. Conversely, the delay imposed on the plaintiff is potentially indefinite. There is no telling how complicated the government&#x27;s investigation may be, whether the allegations of the particular civil plaintiff are merely the tip of an iceberg that will result in a lengthy and open-ended investigation, what priority the government assigns to the investigation, whether it will result in charges that will have to</p><p block-type='Text'>to unseal the victims&#x27; names so that he may make use similar press efforts to impugn their credibility.</p><p block-type='Text'>be litigated, or how time-consuming the resulting criminal case will be. Under these circumstances, the likelihood that a civil party can make the necessary showing to obtain the &quot;extraordinary&quot; remedy of a stay is inevitably much reduced.</p><p block-type='Text'>Sterling Nat&#x27;l Bank, 175 F. Supp. 2d at 577 (internal citations omitted).</p><p block-type='Text'>The First Circuit has noted that the decision whether to grant a stay &quot;is highly nuanced ... [and] involves competing interests. Balancing these interests is a situation-specific task, and an inquiring court must take a careful look at the idiosyncratic circumstances of the case before it.&quot; Microfinancial, supra, 385 F.3d at 78. Epstein&#x27;s case is more idiosyncratic than most.</p><p block-type='Text'>As the Court aptly noted in its Order denying Epstein&#x27;s first motion to stay the civil proceedings, Epstein has not been indicted and there are no criminal proceedings pending against him.&#x27; The resurrection of criminal proceedings against Epstein lies entirely within Epstein&#x27;s own hands, by performing or not performing under the terms of the NPA. This tips the balance of equities even further in favor of the plaintiffs. Epstein makes allegations that the U.S. Attorney&#x27;s Office has unfettered discretion in determining breaches of the NPA, but this is no different than in any contractual setting. If one party believes that there has been a breach, it may seek the remedy set forth in the contract. If the other party believes that</p><p><sup>&#</sup>x27;Epstein points to provisions requiring him to maintain certain evidence &quot;inviolate&quot; as proof that the grand jury investigation is still active. These provisions are meant only to insure that easily destroyed evidence identified through the investigation, such as computer equipment, that is still in Epstein&#x27;s control, will still be available to investigators if Epstein does, in fact, breach the NPA. Epstein is well aware that litigation concerning those matters have been removed from the Court&#x27;s docket, at the insistence of the United States, because it fully halted its investigation in accordance with the terms of the NPA.</p><p block-type='Text'>there has been no breach, it has a remedy at law or equity. In this situation, Epstein would be entitled to seek dismissal of the indictment. See United States v. Beeks, 167 Fed. Appx 777 (1 1 th Cir. 2006); United States v. 138 Fed. Appx. 965 (9th Cir. 2005); United States v. , 393 F.3d 540 (5th Cir. 2004).</p><p block-type='Text'>Epstein argues that because he is seeking a finite period of delay — until the time that he asserts that the NPA &quot;expires&quot; — and that, thereafter, he will promptly provide full and complete responses to all discovery, the harm to the plaintiffs is de minions. With all respect, this overlooks a number of obvious issues. First, if a stay is imposed until Epstein&#x27;s proposed &quot;expiration date,&quot; it affords Epstein one of two incentives: (a) to delay any intended breach until a time when he believes that the United States has no remedy and then to breach the agreement with impunity (Le, to use the NPA as a shield and a sword); or (b) to delay the civil litigation as long as possible (until shortly before the &quot;expiration&quot; of the NPA), and then, after criminal charges have been filed, to seek a mandatory stay of the civil cases until the criminal case is resolved. Thus, contrary to the assertions of Epstein, the delay is not limited but, instead, is &quot;potentially indefinite,&quot; as Sterling Bank warns. If the U.S. Attorney&#x27;s Office were to proceed criminally, the litigation would likely be very lengthy, and would result in an even greater delay to the plaintiffs.5</p><p><sup>5</sup>The United States also notes that this finite termination to Epstein&#x27;s exposure to potential criminal consequences is illusory. The NPA addresses only certain victims identified during the course of the government&#x27;s investigation. To the extent that any of the plaintiffs who have already filed suit against Epstein do not fall within that group, the NPA does not address potential charges based upon crimes committed against them. The NPA also does not bind any other state or federal prosecutor from pursuing charges for criminal acts committed within their jurisdiction(s). The federal statute of limitations for offenses against children is ten years or the life of the child,</p><p block-type='Text'>The factors to consider include: &quot;(i) the interests of the civil plaintiff in proceeding expeditiously with the civil litigation, including the avoidance of any prejudice to the plaintiff should a delay transpire; (ii) the hardship to the defendant, including the burden placed upon him should the cases go forward in tandem; (iii) the convenience of both the civil and criminal courts; (iv) the interests of third parties; . (v) the public interest() (vi) the good faith of the litigants (or the absence of it) and (vii) the status of the cases.&quot; Microfinancial, 385 F.3d at 78 (citations omitted).</p><p block-type='Text'>In considering those factors, the United States respectfully recommends to the Court that all of the factors weigh against a stay. In making its decision, the Court should consider that, unlike all of the cases cited herein, Epstein seeks to stay not one suit involving a single plaintiff, but more than a dozen suits filed by individual plaintiffs. Each of those plaintiffs, in turn, impliedly asserts that she is a &quot;crime victim&quot; with the &quot;right to full and timely restitution&quot; and the &quot;right to proceedings free from unreasonable delay.&quot; 18 U.S.C. § 3771(a)(6) &amp; (7). As noted above, one of the purposes of the NPA was to provide these rights to victims identified in the Government&#x27;s investigation. Thus, this factor weighs more heavily for the plaintiffs than in the average civil dispute as it embodies both the plaintiffs&#x27; and the public&#x27;s interests. The victims who were identified in the government investigation, by and large, were without financial assets and had significant counseling needs that could</p><p>whichever is longer. 18 U.S.C. § 3283. Thus, for Epstein (or any other person accused of sexually abusing children) to &quot;wait out&quot; any chance of criminal liability, the court would have to stay civil litigation until all of the plaintiffs have died.</p><p block-type='Text'>be remedied through obtaining restitution from Epstein. In addition to those needs, they have legitimate concerns about memories fading, witnesses becoming unavailable, and dissipation of Epstein&#x27;s assets while the matter is stayed. On the other hand, while the potential harm to the defendant normally weighs in the defendant&#x27;s favor, in this case, Epstein has significant control over whether the criminal investigation remains in abeyance and whether criminal charges are ever filed.</p><h1>CONCLUSION</h1><p block-type='Text'>In accordance with the Court&#x27;s Order, the United States hereby submits that it is not aware of any &quot;special circumstances&quot; that warrant staying all of the civil cases pending the &quot;expiration&quot; of the NPA.</p><p block-type='Text'>Respectfully submitted,</p><p block-type='Text'>R. ALEXANDER ACOSTA UNITED STATES ATTORNEY</p><p block-type='Text'>t By: A. r Villafafia A. VILLAFANA Assistant United States Attorney Florida Bar No. 0018255 500 East Broward Boulevard, 7th Floor Ft. Lauderdale, FL 33394 Telephone: 954-356-7255 Facsimile: 954-356-7230</p><h2>CERTIFICATE OF SERVICE</h2><p block-type='Text'>I HEREBY CERTIFY that on May 28, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. According to the Court&#x27;s website, counsel for all parties are able to receive notice via the CM/ECF system.</p><blockquote><p block-type='Text'>ti a lVILLAFARA Assistant United States Attorney !alarm</p></blockquote>
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marker2/court-doe-v-epstein-80469/EFTA02750467/EFTA02750467.md

@@ -0,0 +1,261 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80119- MARRA
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232- MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 4,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CV-80380- MARRA/
+
+JANE DOE NO. 5, CASE NO.: 08-CV-80381- MARIZA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994- MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 7,
+
+Plaintiff,
+
+CASE NO.: 08-CV-80993- MARRA
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+C.M.A., CASE NO.: 08-CV-80811-MARRA/JOHNSON
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE, CASE NO.: 08-CV-80893-MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. II, CASE NO.: 08-CV-80469-
+
+MA RRAi
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 101, CASE NO.: 09-CV-80591-
+
+MARRA
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+JANE DOE NO. 102,
+
+Plaintiff,
+
+CASE NO.: 09-CV-80656-
+
+MARRA
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## PLAINTIFFS JANE DOE NO. 101 AND JANE DOE NO. 102's REPLY IN SUPPORT OF MOTION TO PROCEED ANONYMOUSLY AND RESPONSE IN OPPOSITION TO MOTION TO COMPEL AND/OR IDENTIFY JANE DOE NO. 101 AND JANE DOE NO. 102 IN THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY'
+
+Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 (together, "Plaintiffs"), by and through their undersigned attorneys, hereby file their Reply in Support of Motion to Proceed Anonymously and Response in Opposition to Motion to Compel and/or Identify Jane Doe No. 101 and Jane Doe No. 102 in Third-Party Subpoenas for Purposes of Discovery, and, as grounds, state as follows:
+
+I. Exposure of Plaintiffs to the public disclosure of their identity and the resultant shame and humiliation accompanying their sexual exploitation is wholly unnecessary and premature, and may cause further damage. Plaintiffs respectfully assert that this Court should first decide the threshold issues of retroactivity and calculation of damages. Plaintiffs, and all other victims of Defendant who have filed an action against Defendant in federal court, will have to litigate these two following threshold issues being reviewed by the Court in the C.M.A. action against Defendant (Case No. 08-CV-80811-MARRA/ 1) whether the most recent version of the statute, which provides for a minimum recovery of \$150,000 (instead of the previous minimum of
+
+Plaintiffs respectfully file this Reply in the consolidated action, as the issue at hand pertains to discovery issues.
+
+\$50,000) applies to cases arising from incidents predating the 2006 amendment to the statute; and 2) whether the applicable minimum amount is recoverable per incident and/or per count, or per victim. Defendant has attempted to force settlements on any victims as possible without considering the possibility that the minimum amount recoverable under 18 U.S.C. § 2255 is \$150,000 per count and/or per incident. Much of this Court's caseload will be alleviated once the Court resolves these issues related to the minimum recovery; at that point, many of Defendant's victims will likely agree to settle for the minimum statutory damages to which they are entitled, thus obviating Defendant's specified need to destroy his victims' anonymity and expose them to further harm and humiliation.
+
+2. This Court has discretion to deny Defendant's Motion to Compel and/or Identify Plaintiffs in Third Party Subpoenas for Purposes of Discovery. See Doe v. Stegall, 653 F.2d 180, 184 (5th Cir. Aug. 10, 1981)2 ("Fed.R.Civ.P. 26(c) vests in the trial court discretion over litigants' requests for protection from 'annoyance, embarrassment, oppression, or undue burden or expense' in the discovery process.") (internal quotation omitted). As more fully discussed in Plaintiffs' Response to Defendant's Motion to Stay, which is adopted and incorporated herein, Defendant waived his right to contest liability in actions filed pursuant to 18 U.S.C. § 2255. Thus, third party discovery is relevant only if Plaintiffs seek recovery of damages in excess of the statutory minimum. Additionally, if and when the parties are ready to proceed with discovery from non-party sources, the Court can put numerous measures in place to maximize Plaintiffs' anonymity. At the outset, Defendant can obtain records from
+
+<sup>2</sup> In Bonner v. City of Prichard. 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane). this circuit adopted as binding precedent all decisions of the former Fifth Circuit handed down before October 1, 1981.
+
+various non-party sources through Plaintiffs' counsel, who can demonstrate and certify that they have obtained the very records being sought, or through an independent special who could be given releases by Plaintiffs to obtain such records on behalf of Defendant to eliminate any question of authenticity or completeness. If Defendant nevertheless insists on conducting his own third-party discovery (needlessly increasing the cost of litigating these actions and causing unnecessary delay), subpoenas seeking documents from sources such as health care providers or employers should not disclose the type of action or identify Defendant. Because of the highly-publicized nature of Defendant's crimes as well as his designation as a sexual offender, the mere mention of Defendant's name in any subpoena or deposition notice will automatically expose the subject Plaintiff as one of Defendant's victims and may result in unnecessary public humiliation. Similarly, records custodian depositions do not require the disclosure of the nature of the action and/or the identity of the defendant in the action.3
+
+3. Defendant's only purpose in opposing Plaintiffs' motions is harassment. Defendant's intentions are clear. He seeks to destroy these young women by outing them as being among his many victims, a pattern of behavior consistent with his status as a designated sex offender. Defendant openly admits to his desire to reveal the victims' names in newspapers so that individuals in their community can come forward to assault their credibility and tarnish their reputations (and, as a result, their dignity). See Defendant's Response in Opposition to Motion to Proceed Anonymously (DE# 5) at y 6 ("[O]nce the Plaintiff is identified, other individuals come forward in the discovery phase with information which often directly contradicts allegations as to the events and
+
+<sup>3</sup> Depending upon claims of Plaintiffs, certain documents will be relevant. At this point, however, Plaintiffs do not waive their privilege to prevent the release of each of their names under the doctor-patient relationship.
+
+damages. For instance, witnesses may testify that Plaintiff was paid by others for similar sexual acts she claims Mr. Epstein forced upon her or that she willingly participated in certain acts(s) that would negate or lessen her damages"). Each of Defendant's victims whom undersigned counsel represents continues to experience trauma and humiliation associated with sexual abuse. See Ellen Bass & Laura M, The Courage to Heal: A Guide for Women Survivors of Child Sexual Abuse 3 (4th ed. 2008) ("The long-term effects of child sexual abuse can be so pervasive that it's sometimes hard to pinpoint exactly how the abuse affected you. It can permeate everything: your sense of self, intimate relationships, sexuality, parenting, working, even your sanity.")4 The U.S. Supreme Court in Coker v. Georgia, 433 U.S. 584, 597 (1977), discussed the grave nature of the crimes at issue in the cases against Defendant, stating:
+
+[Rape] is highly reprehensible, both in a moral sense and in its almost total contempt for the personal integrity and autonomy of the female victim ... Short of homicide, it is the "ultimate violation of self."
+
+Defendant committed crimes constituting the "ultimate violation of self" against minors. Because of the disdainful nature of these types of crimes, courts, including the Eleventh Circuit, "have carved out a limited number of exceptions to the general requirement of disclosure, which permit plaintiffs to proceed anonymously." Roe v. Aware Woman Or. for Choice, Inc., 253 F.3d 678, 685 (11th Cir. 2001) (internal citation omitted). "The
+
+<sup>4</sup> Although some Plaintiffs no longer live in the Palm Beach area, this should not undermine Plaintiffs' need for anonymity. As the Court in Doe No. 2 v. Kona), 242 F.R.D. 193, 197 (E.D.N.Y. 2006) (internal citation omitted), points out, "Mt is now possible to 'determine whether a given individual is a party to a lawsuit in federal court anywhere in the country by the simplest of computer searches, to access the docket sheet of any such case electronically, and ... that entire case files will be accessible over the Internet." Given the ease with which the public could access court files in these cases, it is reasonable that Plaintiffs' fears extend beyond ostracism in the Palm Beach community. The Palm Beach Post is available online all over the world. In addition, many of Plaintiffs' family members remain in the Palm Bcach area and remain unaware of their daughter/granddaughter/nicce's involvement in Defendant's sordid child sex exploitation enterprise. Furthermore. Plaintiffs are exposed to harassment through social networking sites such as Faccbook and MySpacc as well as other forms of online harrassment.
+
+ultimate test for permitting a plaintiff to proceed anonymously is whether the plaintiff has a substantial privacy right which outweighs the customary and constitutionally-embedded presumption of openness in judicial proceedings." Id. (internal quotation and citation omitted).
+
+4. Cases regarding sexual assault are the paradigmatic examples of the type of highly sensitive and personal matter that warrant a grant of anonymity. See Doe No. 2 v. Kolko, 242 F.R.D. 193, 195-98 (E.D.N.Y. 2006) (adult plaintiff, who, many years later, alleged that he was sexually abused by rabbi at private Jewish school when he was a child, was entitled to proceed anonymously because he feared retaliation and ostracism from his community); Doe v. 202 F.R.D. 173, 176 (E.D. Pa. 2001) (sexual assault victim granted use of pseudonym); Doe v. M, 105 F. Supp. 2d 40, 44 (E.D.N.Y. 1999) (victim of assault, molestation, and sexual abuse granted anonymity because victim otherwise psychologically and emotionally unable to proceed with action); Roe v. Borup, 500 F. Supp. 127, 130 (E.D. Wis. 1980) ("It is beyond argument that [a suit involving charges of sexual abuse of a child] is a highly sensitive issue"; thus, plaintiffs were entitled to use fictitious names in prosecuting the suit); see also Doe v. Blue Cross & Blue Shield United of Wis., 112 F.3d 869, 872 (7th Cir. 1997) ("[F]ictitious names are allowed when necessary to protect the privacy of children, rape victims, and other particularly vulnerable parties or witnesses."). The intensely personal nature of sexual exploitation creates an unusual case, and, in such a case, the general policy of full disclosure should give way to a policy of protecting privacy in a very private matter. This protection is especially necessary when the Court is dealing with young women who recently were sexually abused as minors.
+
+5. Defendant is using the threat of publicity to attempt to intimidate victims to cause them not to file suit or to settle their claims for the absolute minimum in order for them to avoid being held up to public ridicule and hostility. His intention to attack the victims is at the heart of the protection afforded by numerous rape shield statutes, of which Defendant and his counsel are surely aware. In 1994, Congress amended the Federal Rules of Evidence to promote the strong social policy of protecting a victim's privacy and encouraging victims of crime to come forward. "The reason for extending Rule 412 to civil cases is equally obvious. The need to protect alleged victims against invasions of privacy, potential embarrassment, and unwarranted sexual stereotyping, and the wish to encourage victims to come forward when they have been sexually molested do not disappear because the context has shifted from a criminal prosecution to a claim for damages or injunctive relief." Fed. R. Evid. 412 advisory committee's note. Rule 412 now provides that, in civil trials in federal court involving alleged sexual misconduct, evidence that the victim engaged in other sexual behavior or evidence offered to prove any alleged victim's sexual predisposition can be admitted only in unusual circumstances, none of which apply to Plaintiffs' cases. Fed. R. Evid. 412 (a), (b). "The rule aims to safeguard the alleged victim against the invasion of privacy, potential embarrassment and sexual stereotyping that is associated with public disclosure of intimate sexual details and the infusion of sexual innuendo into the factfinding process. By affording victims protection in most instances, the rule also encourages victims of sexual misconduct to institute and to participate in legal proceedings against alleged offenders." Fed. R. Evid. 412 advisory committee's note; see also Michigan v. Lucas, 500 U.S. 145, 149-50 (1991) (Rape shield statutes represent the valid legislative determination that victims of rape and
+
+attempted rape "deserve heightened protection against surprise, harassment, and unnecessary invasions of privacy."); United States v. Elbert, 561 F.3d 771, 776-77 (8th Cir. 2009) (evidence that child plaintiffs had previously engaged in prostitution was rightfully excluded in federal sex trafficking suit); Stephens v. 13 F.3d 998, 1010 (7th Cir. 1994) (Cummings, C.J., dissenting) ("The Indiana rape shield statute furthers laudable and pragmatic goals. It protects victims from needless exposure of their sexual past conduct; [and] ensures that the focus of rape trials remains the guilt or innocence of the accused rather than the sexual history of the complainant."); United States v. Kasto, 584 F.2d 268, 271-72 n.3 (8th Cir. 1978) ("[U]nchastity of a victim has no relevance whatsoever to [the victim's] credibility as a witness. Such a proposition would `necessarily imply the absurd (corollary) that the extramarital sexual history of a female witness would be admissible to impeach her credibility in any case in which she testified.") (internal citation omitted). Procedural protections such as the rape shield statutes reduce the embarrassment and anguish of trial, encouraging victims to report sexual offenses and offendors. "Without the protection provided by rape shield statutes, victims may find trial an ordeal not worth enduring." Stephens, 13 F.3d at 1010 (Cummings, C.J., dissenting) (quoting 124 Cong. Rec. H 11944 (1978) (statement of Rep. Elizabeth Holtzman)); see Fed. R. Evid. 412 advisory committee's note ("Too often in this country victims of rape are humiliated and harassed when they report and prosecute the rape. ... [R]ape trials become inquisitions into the victim's morality, not trials of the defendant's innocence or guilt ...."). Indeed, "many [victims] find the trial almost as degrading as the rape itself." Fed. R. Evid. 412 advisory committee's note.
+
+6. In addition, Congress enacted the Child Victims' and Child Witnesses' Rights Act (18 U.S.C. § 3509) in an effort to provide protection for victims who, while minors, were victims of physical abuse, sexual abuse, or sexual exploitation, or who have witnessed a crime committed upon another. One of the primary protections provided by the statute is the restriction on the disclosure of the name of, or other information concerning, the victim. See 18 U.S.C. § 3509(d)(3) (2008). Further, pursuant to 18 U.S.C. § 3509(d)(2), "[a]ll papers to be filed in court that disclose the name of or any other information concerning a child shall be filed under seal without necessity of obtaining a court order."
+
+7. Indeed, numerous states, including Florida and New York, have enacted laws to protect the anonymity of sexual assault victims. See Fla. Stat. §§ 794.024, 794.026 (2008); N.Y. Civ. Rights Law § 50-b (McKinney 2009). In 1994, the Florida Legislature passed The Crime Victims Protection Act. The legislative stated purpose for passage of the Act was "to protect the identity of victims of sexual crimes." Ha. AGO 2003-56, 2003 WL 22971082 (Dec. 15, 2003) ("[T]he Legislature intended to make the identity of a victim of a sexual crime confidential in a court record or proceeding.") Under Florida Section 794.024 of the Florida Statutes, court records that identify the name and/or address of a victim of a sexual crime are presumed to be confidential and exempt from public access. Id. That statute further imposes criminal and civil liability for the disclosure or communication of information identifying the victim of a sexual crime. Ha. AGO 2003-56, 2003 WL 22971082 (citing Ha. Stat. §§ 794.024, 794.026 (2008)). Similarly, upon approving New York's rape shield law, then Governor Mario stated, "[S]exual assault victims have unfortunately had to endure a terrible
+
+invasion of their physical privacy. They have a right to expect that this violation will not be compounded by a further invasion of their privacy." 1991 N.Y. Sess. Laws page nos. 2211-12, quoted in Kolko, 242 F.R.D. at 196 (internal citations omitted).
+
+8. Finally, Defendant should be estopped from outing his victims. Plaintiffs attempted to utilize the process established by the Non-Prosecution Agreement ("NPA") with the reasonable expectation that a specific purpose of the NPA was to allow Defendant's victims to maintain anonymity, only to be subjected to deliberate and unreasonable delays and Defendant's failure to engage in meaningful, good faith settlement discussions. This left Plaintiffs no choice but to file suit. Under these circumstances, Defendant should be estopped from seeking to lift anonymity.
+
+9. Many of Defendant's victims are awaiting this Court's decision regarding whether they will be allowed to proceed anonymously before making the difficult decision as to whether to pursue their claims against Defendant. All of Defendant's victims and any future victims of sexual exploitation must know that they can protect what remains of their personal dignity when appealing to the Federal Courts for justice.
+
+WHEREFORE, Plaintiffs respectfully move this Court to grant Plaintiffs' Motion to Proceed Anonymously and to deny Defendant's Motion to Compel and/or Identify Jane Doe No. 101 and Jane Doe No. 102 in Third-Party Subpoenas for Purposes of Discovery.
+
+Date: May 29, 2009
+
+Respectfully submitted,
+
+PODHURST ORSECK, P.A. Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Bar No. 040856 rjosefsberg@podhurst.com Katherine W. Ezell Fla. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+## CERTIFICATE OF SERVICE
+
+WE HEREBY CERTIFY that, on this 29th day of May, 2009, we electronically filed the foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing document is being served this day on all counsel of record identified on the attached Service List either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+Respectfully submitted,
+
+PODHURST ORSECK, P.A. Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102
+
+By: s/Katherine W. Ezell Robert C. Josefsberg Fla. Bar No. 040856 rjosefsberg@podhurst.com Katherine W. Ezell Fla. Bar No. 114771 kezell@podhurst.com City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382
+
+**SERVICE LIST**
+
+JANE DOE NO. 2 v. JEFFREY EPSTEIN  
+Case No. 08-CV-80119-MARRA/[REDACTED]  
+United States District Court, Southern District of Florida
+
+Robert Critton, Esq.  
+Michael J. Pike, Esq.  
+Burman, Critton, Luttier & Coleman LLP  
+515 North Flagler Drive, Suite 400  
+West Palm Beach, FL 33401  
+Phone: (561) 842-2820  
+Fax: (561) 515-3148  
+[rcrit@bclclaw.com](mailto:rcrit@bclclaw.com)  
+[mpike@bclclaw.com](mailto:mpike@bclclaw.com)  
+*Counsel for Defendant, Jeffrey Epstein*
+
+Jack Goldberger, Esq.  
+Atterbury, Goldberger & Weiss, P.A.  
+250 Australian Avenue South, Suite 1400  
+West Palm Beach, FL 33401  
+Phone: (561) 659-8300  
+Fax: (561) 835-8691  
+[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net)  
+*Co-Counsel for Defendant, Jeffrey Epstein*
+
+Bruce E. Reinhart, Esq.  
+Bruce E. Reinhart, P.A.  
+250 South Australian Avenue, Suite 1400  
+West Palm Beach, FL 33401  
+Phone: (561) 202-6360  
+Fax: (561) 828-0983  
+[ecf@brucereinhartlaw.com](mailto:ecf@brucereinhartlaw.com)  
+*Counsel for Co-Defendant,* [REDACTED]
+
+Jack Scarola, Esq.  
+Jack P. [REDACTED], Esq.  
+Searcy Denney Scarola Barnhart & Shipley, P.A.  
+2139 Palm Beach Lakes Boulevard  
+West Palm Beach, Florida 33409  
+Phone: (561) 686-6300  
+Fax: (561) 383-9456  
+[jsx@searcylaw.com](mailto:jsx@searcylaw.com)  
+[jph@searcylaw.com](mailto:jph@searcylaw.com)  
+*Counsel for Plaintiff C.M.A.*
+
+Adam Horowitz, Esq. Stuart Mermelstein, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Blvd., Suite 2218 Miami, FL 33160 Phone: (305) 931-2200 Fax: (305) 931-0877 ahorowitz@sexabuseattomey.com smermelstein@sexabuseattoney.com Counsel for Plaintiffs in Related Case Nos. 08-80069, 08-80119,08-80232, 08-80380, 08- 80381, 08-80993, 08-80994
+
+Spencer Todd Kuvin, Esq. Theodore Jon Leopold, Esq. Leopold Kuvin, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Phone: (561) 515-1400 Fax: (561) 515-1401 skuvin@leopoldkuvin.com tleopold@leopoldkuvin.com Counsel for Plaintiff in Related Case No. 08-08804
+
+Richard Willits, Esq. Richard H. Willits, P.A. 2290 10th Ave North, Suite 404 Lake Worth, FL 33461 Phone: (561) 582-7600 Fax: (561) 588-8819 lawyerwillits@aol.com reelrhw @hotmail.com Counsel for Plaintiff in Related Case No. 08-80811
+
+Brad , Esq. Law Office of Brad & Associates, LLC 2028 Street, Suite 202 Hollywood, FL 33020 Phone: (954) 414-8033 Fax: (954) 924-1530 bedwardserra-law.com be@bradedwardslaw.com Counsel for Plaintiff in Related Case No. 08-80893
+
+Isidro Manuel Esq. Elkins & Boehringer 224 Datum Avenue, Suite 900
+
+West Palm Beach, FL 33401
+
+Phone: (561) 832-8033
+
+Fax: (561) 832-7137
+
+isidrogarcia@bellsouth.net
+
+Counsel for Plaintiff in Related Case No. 08-80469

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