UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. _________________________________/ Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 __________________________________/ PLAINTIFF JANE DOE’S NOTICE OF NINETY DAYS EXPIRING ON MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECIEVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $15 MILLION BOND TO SECURE POTENTIAL JUDGMENT [DE 165] Plaintiff, Jane Doe, pursuant to Local Rule 7.1.B.3, hereby gives notice her Motion for Appointment of a Receiver to Take Charge of Property of Epstein has been pending for more than 90 days. 1. On June 19, 2009, Jane Doe filed her Motion for Injunction Restraining Fraudulent Transfer of Assets Appointment of a Receiver to Take Charge of Property of Epstein, and to Post a $15 Million Bond to Secure Potential Judgment [DE 165]. 2. On July 13, 2009, after Epstein was granted a continuance, he filed a response in opposition [DE 198]. Case 9:08-cv-80119-KAM Document 385 Entered on FLSD Docket 10/30/2009

Page 1 of 4 CASE NO: 08-CV-80119-MARRA/JOHNSON 2 3. On July 20, 2009, Jane Doe filed a motion for leave to file an affidavit in support of her motion [DE 213]. (Epstein filed a response to this particular motion on August 5, 2009 [DE 244]) 4. On July 23, 2009, Jane Doe filed a reply in support of her motion [DE 217]. 5. Today, contemporaneously with the filing of this notice, Jane Doe also filed a Motion for Leave to Provide Recently-Obtained Deposition Testimony and Affidavit Demonstrating Fraudulent Transfers by Epstein in Support of Motion for Appointment of a Receiver to Take Charge of Property of Epstein. 6. For the reasons outlined in her pleadings – including in particular her opening pleading outlining the protections of the Florida Uniform Fraudulent Conveyance Act and her recent pleading demonstrating that fraudulent transfers by Epstein are on-going – Jane Doe respectfully requests that the Court grant her motion promptly and appoint a receiver to take charge of Epstein’s assets and provide the other requested relief. Jane Doe respectfully requests that the Court act on her motion as soon as possible, to prevent Epstein from completing his fraud and hiding all of his substantial assets before the appointment of a receiver. DATED October 30, 2009 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Case 9:08-cv-80119-KAM Document 385 Entered on FLSD Docket 10/30/2009

Page 2 of 4 CASE NO: 08-CV-80119-MARRA/JOHNSON 3 Telephone (954) 522-3456 Facsimile (954) 527-8663 Florida Bar No.: 542075 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected] CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October 30, 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 on 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 filed Notices of Electronic Filing. /s/ Bradley J. Edwards Bradley J. Edwards Case 9:08-cv-80119-KAM Document 385 Entered on FLSD Docket 10/30/2009

Page 3 of 4 CASE NO: 08-CV-80119-MARRA/JOHNSON 4 SERVICE LIST Jane Doe v. Jeffrey Epstein United States District Court - Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Isidro Manual Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg [email protected] Adam D. Horowitz [email protected] Stuart S. Mermelstein [email protected] William J. Berger [email protected] Case 9:08-cv-80119-KAM Document 385 Entered on FLSD Docket 10/30/2009