Epstein Secrets

v. JEFFREY EPSTEIN, Defendant. MOTION TO STRIKE REFERENCES TO NON-PROSECUTION AGREEMENT OR, IN THE ALTERNATIVE, TO LIFT PROTECTIVE ORDER BARRING JANE DOE'S ATTORNEY'S FROM REVEALING PROVISIONS IN THE AGREEMENT Plaintiff, Jane Doe, hereby moves this Court to strike all references to a "non- prosecution

ent in parallel litigation under the Crime Victim's Rights Act. Doe v. United States, No. 9:08-CV-80736-KAM. The agreement, however, was provided to Jane Doe's counsel subject to a protective order. That protective order precludes Jane Doe's 3 EFTA00722661 Case 9:08-cv-80893-KAM Document 32 Entered on

ile Florida r N a.4 m E-mail: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 9, 2009, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing is being served this day upon all counsel of record identified on the attached Service List in the manner specif

ff, JEFFREY EPSTEIN, Defendant. MOTION TO STRIKE REFERENCES TO NON-PROSECUTION AGREEMENT OR. IN THE ALTERNATIVE, TO LIFT PROTECTIVE ORDER BARRING JANE DOE'S ATTORNEY'S FROM REVEALING PROVISIONS IN THE AGREEMENT Plaintiff, Jane Doe, hereby moves this Court to strike all references to a "non- prosecution

ement in parallel litigation under the Crime Victim's Rights Act. Doe United States, No. 9:08-CV-80736-KAM. The agreement, however, was provided to Jane Doe's counsel subject to a protective order. That protective order precludes Jane Doe's 3 EFTA00234762 Case 9:08-cv-80893-KAM Document 32 Entered on

75 E-mail: [email protected] CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 9, 2009, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing is being served this day upon all counsel of record identified on the attached Service List in the manner specif

ntil late 2010. Epstein's Motion to Stay filed in the instant case is identical to the ones he filed in Jane Doe v. Epstein, Case. No. 08-CV-90893, Jane Doe No. 2 v. Epstein Case No. 08-CV- 80119, Jane Doe No. 3 v. Epstein, Case No. 08-CV-80232, Jane Doe No. 4 v. Epstein, Case No. 08-CV-80380, Jane Doe N

Memorandum of Law Page 3 of 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 24, 2009, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified above via transmission of Notices of Elect

against the Defendant in this case. In this Court's Opinion and Order on Motion to Dismiss and Motion for More Definite Statement in the case styled Jane Doe No. 6 v. Jeffrey Epstein Case No. 08-80994-CIV-Marra ("Jane Doe No. 6) this Court rejected any contention by the Defendant that the Supreme Court's

mended Complaint Page 17 of 18 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 13, 2009, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified above via transmission of Notices of Elect

n filed an identical Motion to Stay in the case Jane Doe v. Epstein, case no. 08- CIV 80893 MARRA/JOHNSON. Plaintiffs concur in the arguments made by Jane Doe's counsel in that case in opposition to Defendant's Motion. (Case no. 08-CIV 80893, DE 31). The same reasoning and arguments apply in the instant cas

33301 Florida Bar No.: 542075 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 9, 2009, I electronically filed the: foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing is being served this day upon all counsel of record identified on the attached Service List in the manner specif

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/JOHNSON CASE NO.: 08-CV-80993-MARRA/JOHNSON CASE NO.: 08-CV-80811-MARR

West Palm Beach. Florida 33409 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 8th, 2009, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified above via transmission of Notices of Elect

TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, v

D Docket 07/30/2008 Page 3 of 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 30, 2008, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record listed below via transmission of Notices of Electroni

REY EPSTEIN and Defendants. EPSTEIN'S RESPONSE TO MOTION TO PRESERVE EVIDENCE [DE 121 Defendant Jeffrey Epstein hereby responds to the plaintiff Jane Doe's motion to preserve evidence, as follows: I. The Certificate of Compliance annexed to the plaintiffs motion states that plaintiff's "counsel confe

Docket 08/22/2008 Page 3 of 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 22, 2008, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the attached Service List in the manner

ions asked and the documents requested .. . ." Id. Here Epstein has made sweeping generalizations about the applicability of the Fifth Amendment to Jane Doe's specific discovery requests. But in his motion, he has merely cobbled together a few grandiose quotations about general Fifth Amendment principles

75 E-mail: [email protected] CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 9, 2009, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing is being served this day upon all counsel of record identified on the attached Service List in the manner specif

et 04/17/2009 Page 5 of 18 Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of the plaintiff, Jane Doe's minority. 21. The above-described acts were perpetrated upon the person of the then minor Plaintiff regularly and on dozens of occasions. 22. In

rds R TH TEIN R• ENFELDT ADLER CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 17, 2009, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing is being served this day upon all counsel of record identified on the attached Service List in the manner specif