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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-804
d 291 (Fla. 3d DCA 1971). Therefore, it is clear in this intentional tort case that punitive damages are an issue. As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and scheme to sexually molest dozens of underage teenage girls.3 Even assuming that the “compelling need” s
tive damages are an issue. As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and scheme
re relevant to punitive damages, among other issues in these cases, and in this regard the Defendant’s tax returns are pertinent and discoverable. Tennant v. Charlton, 377 So.2d 1169 (Fla. 1979) (holding that party may obtain tax returns for purposes of net worth discovery on issue of punitive damages
JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ________________________________
admission of the genuineness, the existence, and Epstein’s control of such records, and thus presents a re
ages. It appears from evidence in this case that Defendant Epstein earns and funnels income among a labyrinth of bu
t’s tax returns are pertinent and discoverable. Tennant v. Charlton, 377 so.2d 1169 (Fla. 1979) (holding
JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ________________________________
es are an issue. As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and scheme
tive damages are an issue. As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and scheme
t’s tax returns are pertinent and discoverable. Tennant v. Charlton, 377 So.2d 1169 (Fla. 1979) (holding
Entities connected to both Jeffrey Epstein and Tennant

Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSON
Alfredo Rodriguez
PERSON
Paul Cassell
PERSONRobert D. Critton
PERSONRobert C. Josefsberg
PERSONMichael J. Pike
PERSON
Adam D. Horowitz
PERSONKatherine W. Ezell
PERSONRichard Horace Willits
PERSON
Jennifer Lopez
PERSONJack Patrick Hill
PERSONIsidro Manuel Garcia
PERSONStuart S. Mermelstein
PERSONSecond Circuit
ORGANIZATIONMermelstein & Horowitz
ORGANIZATIONthe Eleventh Circuit
ORGANIZATIONMyers
PERSON
John Doe
PERSON