locate and interview 11 more girls? 12 A Yes. 13 Q Let's turn to the specific evidence reporting 14 the overt acts and offenses relating to Jane Doe's 1 15 through 5. I know that every member of the grand jury has 16 a copy of the draft indictment before them, and also a 17 chart. 18 Do yo

locate and interview 11 more girls? 12 A Yes. 13 Q Let's turn to the specific evidence reporting 14 the overt acts and offenses relating to Jane Doe's 1 15 through 5. I know that every member of the grand jury has 16 a copy of the draft indictment before them, and also a 17 chart. 18 Do yo

locate and interview 11 more girls? 12 A Yes. 13 Q Let's turn to the specific evidence reporting 14 the overt acts and offenses relating to Jane Doe's 1 15 through 5. I know that every member of the grand jury has 16 a copy of the draft indictment before them, and also a 17 chart. 18 Do yo

the evidence supporting various overt acts and charges 4 related to Jane Does number 1 and 2? 5 A Yes. 6 Q Today we are going to start with Jane Doe 7 number 3. Can you tell the Grand Jury who that is and 8 summarize briefly your previous testimony about her. 9 A Jane Doe number 3 is I and

the evidence supporting various overt acts and charges 4 related to Jane Does number 1 and 2? 5 A Yes. 6 Q Today we are going to start with Jane Doe 7 number 3. Can you tell the Grand Jury who that is and 8 summarize briefly your previous testimony about her. 9 A Jane Doe number 3 is I and

the evidence supporting various overt acts and charges 4 related to Jane Does number 1 and 2? 5 A Yes. 6 Q Today we are going to start with Jane Doe 7 number 3. Can you tell the Grand Jury who that is and 8 summarize briefly your previous testimony about her. 9 A Jane Doe number 3 is I and

tered on FLSD Docket 02/21/2019 Page 1 of 33 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE I AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Parti

. (DE 407 at ¶ 5.) The FBI ultimately determined that both Jane Doe 1 and Jane Doe 2 were victims of sexual abuse by Epstein while they were minors. Jane Doe 1 provided information about her abuse and Jane Doe 2's abuse to the FBI on August 7, 2007. (DE 407 at ¶ 6.) From January of 2007 through September

TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN OPPOSITION TO PROPOSED REMEDIES Bradley J. Edwards Edwards Pottin er LP Paul G. Cassell Pro Hac Vice T

also extends to "Other Potential Defendants," defined as any "other person or entity would could have been included as a potential defendant" in the Jane Does lawsuit alleging sex abuse. Obviously, the United States was a not sex abuser and could not have been included in the lawsuit against Epstein. 42

08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 _____________________________________/ PLAINTIFF, JANE DOE’S MOTION FOR A PROTECTIVE ORDER ENFORCING NO CONTACT ORDER AND INCORPROATED MEMORANDUM OF LAW Plaintiff, Jane Doe, hereby joins in Jane Doe Nos. 2-

m when he pled guilty to a state sex offense. 13. If Epstein suddenly and genuinely found some reason that he needs to attend the deposition of Jane Doe2 and believes that Judge Pucillio’s order unduly or unfairly restricts his ability to do so, he is free to take up the matter with Judge Pucillio.

eement with the requested , it is HEREBY ORDERED and ADJUDGED that: Defendant shall serve his Response in Opposition to the Rule 4 Appeal filed by Jane Does 2-8 on or before November 3, 2009. DONE and ORDERED this~ay of b cro.so_ , 2009. Kenneth A. Marra United States District Judge Courtesy Copies:

OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

. (DE 407 at ¶ 5.) The FBI ultimately determined that both Jane Doe 1 and Jane Doe 2 were victims of sexual abuse by Epstein while they were minors. Jane Doe 1 provided information about her abuse and Jane Doe 2's abuse to the FBI on August 7, 2007. (DE 407 at ¶ 6.) From January of 2007 through September

tered on FLSD Docket 02/21/2019 Page 1 of 33 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Parti

656, 09-80802, 09-81092 ____________________________________/ OMNIBUS ORDER THIS CAUSE is before the Court on the following motions: (1) Plaintiff’ Jane Doe’s Motion for Protective Order Barring Second Deposition and for Sanctions (D.E. #378); and, (2) Plaintiff Jane Doe No. 4's Motion for Protective Order

n’s Motion to Compel (D.E. #s 67 & 68), which sought information related to Plaintiff’s past sexual history. All agree that there were instances at Jane Doe 4's initial deposition where she was instructed by her counsel not to answer questions “relat[ed] to sexual partners’ names or sexual positions.” Jane

PSTEIN, Defendant. __________ ___:! JANE DOE NO. 7, Plaintiff, JEFFREY EPSTEIN Defendant. I C.M.A., Plaintiff, JEFFREY EPSTEIN Defendant. I JANE DOE, Plaintiff, JEFFREY EPSTEIN et al, Defendants. I DOE II, Plaintiff, JEFFREY EPSTEIN et al, Defendants. I CASE NO.: 08-80994-CIV-MARRA/JOHNS

ase 9:08-cv-80119-KAM Document 152 Entered on FLSD Docket 06/10/2009 Page 1 of 8 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, JEF

ey Epstein, in an abundance of caution requests that the court enter the attached proposed Agreed Order which shall not preclude him from attending Jane Does' mediations or the trials of these cases. Case 9:08-cv-80119-KAM Document 542 Entered on FLSD Docket 05/11/2010 Page 2 of 3 Rule 7 .1 Certifi

Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidrogarcia@b

______ __:! EPSTEIN'S RESPONSE IN OPPOSITION TO JANE DOE'S MOTIONS FOR PROTECTIVE ORDER BARRING SECOND DEPO

scheduled for November 13, 2009. Nevertheless, as Jane Doe's deposition will most likely occur during the we

unsel, requesting a 90-day extension of time in which to confer and propose procedural steps for determining an appropriate remedy. Through counsel, Jane Doe I and 2 conferred with the Office, noting that this case has been in litigation for more than a decade — requesting that a resolution be expedited. Th

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-ev-80736-ICAM JANE DOE 1 AND JANE DOE 2, Petitioners, v. UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S POSITION ON THE PROCEDURES TO BE FOLLOWED TO DETERMINE A REMEDY FOR THE GOVERNMENT'S VIOLATION OF THE CRIME VICTIMS' RIGHTS ACT J

was cheating on him?” (Exh. 3, p. 132); Case 9:08-cv-80119-KAM Document 534 Entered on FLSD Docket 04/27/2010 Page 3 of 8 ----- 4 * “[Jane Doe No. 4] testified also in deposition that she had been—there had been a videotape made of her and another female in various positions that some of he

; Plaintiffs Jane Does 2-7’s Response to Defendant’s Motion to Compel and/or Identify Plaintiffs in the Style of this Case (D.E. 144); Plaintiffs Jane Does’ 2-7 Motion for Protective Order and Incorporated Memorandum of Law (D.E. 223); Plaintiffs Jane Doe Nos. 2-8’s Motion for Protective Order as to Jef

e's Injunction Motion Page 5 of24 relief requested by Jane Doe. For the following reasons, the Court must deny Jane Doe's Injunction Motion. II. JANE DOE'S STATEMENT OF MATERIAL FACTS IS BASED ON SPECULATION AND HEARSAY AND CONTAINS NO MATERIAL "FACTS" Jane Doe's "Statement of Material Facts" relies h

JANE DOE NO. 102, CASE NO.: 09-80656-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. I EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $1

________________________________/ PLAINTIFF, JANE DOE’S MOTION FOR A PROTECTIVE ORDER ENFORCING NO CONTA

reason that he needs to attend the deposition of Jane Doe2 and believes that Judge Pucillio’s order unduly o

0, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 __________________________________/ PLAINTIFF, JANE DOE’S MOTION FOR ORDER PERMITTING LEGAL COUNSELTO ATTEND INDEPENDENT MEDICAL EXAMINATION AND INCORPORATED MEMORANDUM OF LAW Plaintiff Jane Doe (Case

8, as well as for a full “legal history,” id. at 9. MEMORANDUM OF LAW 5. As is readily apparent from the questions that will be asked during Jane Doe’s IME, many legal issues will arise. In particular, Jane Doe will have to determine whether to assert various privileges with regard to some of the

t met the exceptional burden of proving to this court that Epstein should be excluded from her deposition. Plaintiff adopts and incorporates all of Jane Doe 2-S's argument with only one additional argument (i.e., that if this court allows Epstein to attend Jane Doe's deposition it would violate the right o

ending the case in the normal course of conducting discovery and filing motions would not be a breach? (Ex. "A," p.30). Mr. Horowitz - counsel for Jane Does 2-7: Subject to your rulings, of course, yes. (Ex. "A," p.30). *** The Court: But you're not taking the position that other than possibly doing s

TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN OPPOSITION TO PROPOSED REMEDIES Bradley J. Edwards Edwards Pottinger LP 425 North Andrews Avenue, Suite

of all relevant circumstances, it is important to understand the very limited reference the victims made to Epstein's NPA in their civil lawsuits. Jane Doe I and 2 filed their civil lawsuits in about September 2008, only after their CVRA petition had been filed — and had succeeded in forcing the USAO- SDF

endant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby files his Joint Notice of Agreement and Plaintiff, Jane Doe's, Motion to Withdraw Plaintiff, Jane Doe's, Motion for Leave to Appear/Attend Independent Medical Examination: 1. On September 15, 2009, Defendan

08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591,09-80656,09-80802,09-81092 _____________ _cl JOINT NOTICE OF AGREEMENT AND PLAINTIFF, JANE DOE'S (#08-80893) MOTION TO,WITHDRA W PLAINTIFF, JANE DOE'S, MOTION FOR ORDER PERMITTING LEGAL COUNSEL TO ATTEND INDEPENDENT MEDICAL EXAMINATION AND IN

ted not only to Epstein's personal tax returns but also to any alleged tax returns filed by any businesses in which Epstein has an interest in - and Jane Doe 2-8's Request for Production attached as Exhibit "A" does not define what tax returns they seek). Although page 3 of DE 426 seems to connote Plaintiff

reasonably calculated to lead to the discovery of admissible evidence. Moreover, the request here is more broad in nature than the requests made by Jane Doe seeking only personal tax returns (i.e., this request here seeks or may seek production of information related not only to Epstein's personal tax re