Epstein Secrets

et (SEC INSTRUCTIONS on THC REVERSE or tat soar NOTICE: Attorneys MUST Indicate All Re-filed I. (a) PLAINTIFFS DEFENDANTS U. 5-67Pcs- X , / r e: Jane Poe (b) Como) of Residence of First Listed Plaintiff fi iiffn OE %KEPT IN U.S. PLAINT'S/ CASES) (e) Anomey's.n. Num. Addina.•40 Telephone swam H 9,

ce of this motion to Jeffrey Epstein, through counsel. Jeffrey Epstein's counsel has entered an appearance in several related civil suits, including Jane Doe v. Jeffrey Epstein, United States District Court, Southern District of Florida, Case No.: 08- CIY-80893-MARRA-JOMVSON. Although Epstein's counsel has

I HEREBY CERTIFY that on September 25, 2008, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. SERVICE LIST Jane Doe 1 and Jane Doe 2 Case No.: 08-80736-CIV-MARRA/JOHNSON United States District Cowl, Southern District of Florida =ME Assistant U.S. Attorney 99 N.E

r to question the sexual offender about, or to arrest the sexual offender for, his or her noncompliance with the requirements of this section: (a) Withholds information frcm, or does not notify, the taw enforcement agency about the sexual offender's noncompliance with the requirements of this section, an

ns, F 10 561-684-65 By: • • IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA JANE DOE, by and through JANE DOE'S Case No: 50 2008 CA 006596 )(XXX MB AB MOTHER, as parent and natural guardian Florida Bar No: 089737 Plaintiff vs. JEFFREY EPSTEIN, HALEY ROBSON

: 17-295 COUNT H Intentional Infliction of Emotional Distress 21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother, individually, repeat and reallege paragraphs 1 through 16 above. 22. Epstein's conduct was intentional or reckle

to question the sexual offender about, or to arrest the sexual offender for, his or her noncompliance with the requirements of this section:; (a) Withholds information from, or does not notify, the Law enforcement agency about the sexual offender's noncompliance with the requirements of this section, an

1 Entered on FLSD Docket 08)18:2008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a, JANE DOE NO. I, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. MOTION TO REMAND Plaintiff Jane Doe moves the Court to remand this act

r to question the sexual offender about, or to arrest the sexual offender for, his or her noncompliance with the roquiromonts of this section: (a) Withholds information from, or does not notify, the law enforcement agency about the sexual offender's noncompliance with the roquiremonts of this section, an

CASE NO.: 08-80069-CIV-MARRA/JOHNSON JANE DOE. NO. 1, by and through JANE DOB's FATHER as parent and natural guardian, and JANE DOB's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFFS' MEMORANDUM OF LAW IN OPPOSITION TO MOTION TO STAY PROCEEDINGS

er to question the sexual offender about, or to arrest the sexual offender for, his Of her noncompliance with the requirement of this section: (a) Withholds information frem, or does not notify, the law enforcement agency about the sexual offender's nomonullance with the requirenvents of this section, an

ss server served Jane Doe at her place of work for a deposition scheduled to take place on February 6, 2008. I See Subpeona attached as Exhibit "A" (Jane Doe's real name has been redacted from the exhibit). 5. The undersigned was forced to call Mr. Goldberger on Friday evening and remind him of our earli

r to question the sexual offender about, or to arrest the sexual offender for, his or her noncompliance with the requirements of this section: (a) Withholds information from, or does not notify, the law enforcement agency about the sexual offender's nascompliance with the requirements of this section, an

ey's Office to the taking of Jane Doe No.1's deposition on February 20, 2008. The parties have also agreed that Mr. Leopold will accept service for Jane Doe's No.1's appearance on that date eliminating the need to use a process server to serve Jane Doe No. 1 . See Exhibit "A" attached. (Jane Doe No. 1's r

r to question the sexual offender about, or to arrest the sexual offender for, his or her noncompliance with the requirements of this section: (a) Withholds information from, or does not notify, the law enforcement agency about the sexual offender's noncompliance with the requirements of this section, an

has met her burden, should the Court consider adopting such extraordinary relief. On its face, the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7. Discussion of Law Requiring the Denial of the Requested Protective Order Rule 26(c)(1XE), Fed.R.Civ P. (2009), gove

r to question the sexual offender about, or to arrest the sexual offender for, his or her noncompliance with the requirements of this section: (a) Withholds information from, or does not notify, the law enforcement agency about the sexual offender's noncompliance with the requirements of this section, an

2 I Epstein, Case No. 09-80656 (S.D. Fla. 2009); Doe No. 8 I Epstein, Case No. 09-80802 (S.D. Fla. 2009)). 6 See also (A-I I at 116) (citing In re: Jane Doe, Case No. 08-80736 (S.D. Fla. 2008)). 7 References to "Supp.A." correspond to the supplemental appendix filed by the Post simultaneous with this b

to question the sexual offender about, or to arrest thct flaunt offender for, his or hor noncompliance with the requirements of this section: (a) Withholds information from, or does not notify, the taw enforcement agency about the sexual offender's noncompliance with the requiremonti of this section, an

has met her burden, should the Court consider adopting such extraordinary relief. On its face, the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7. Discussion of Law Requiring the Denial of the Requested Protective Order Rule 26(c)(1XE), Fed.R.Civ P. (2009), gove

r to question the sexual offender about, or to arrest the sexual offender for, his or her noncompliance with the requirements of this section: (a) Withholds information from, or does not notify, the law enforcement agency about the sexual offender's noncompliance with the requirements of this section, an