Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLI

were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 25. Epstein's conduct caused severe emotional distress to Janc Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional distress and damage to Jane Doe, or Epstein a

Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 25. Epstein's conduct caused severe emotional distress to Janc Doe. Epstein knew or had

would cause emotional trauma and damage to Jane Doe's parents. 25. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiffs Jane D

1308065 COUNT II 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 rcallege paragraphs 1 through 16 above. 22. Epstein's conduct was intentional or reckle

ww.hermanlaw.com SDNY_GM_00328643 EFTA_00201395 EFTA01308071 24. As a direct and proximate result of Epstein's intentional or reckless conduct. Jane Doc, has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE. Plaintiff Jane Doe No. 2 demands judgment against Defendant Jef

2728833 COUNT II 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

would cause emotional trauma and damage to Jane Doe's parents. 25. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiffs Jane D

of Florida. She is a minor under the age of 18 years. 2. Jane Doe's Father brings this action individually and as parent and natural guardian of Jane Doc. Jane Doe's Father is a citizen and resident of the State of Florida. 3. Jane Doe's Stepmother brings this action individually. Jane Doe's Stepmoth

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

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'. Jeffrey Epstein, United States District Court, Southern District of Florida, Case No.: 08- CIY-80893-MARRA-JOHNSON. Although Epstein's counsel has n

Clerk theolyil e cad dwa. IS CI INSTRUCTIONS ON THE REVERS( Of THE FOAMS NOTICE: Altorneys MUST Indicate All Re-filed I. (a) PLAINTIFFS -177 re: Jane Poe DEFENDANTS 5-thfeso/ - fttectagi OW 0 D.C. JULY 7, 2008 STEVEN M.LARIMORE CLERK U.S. 01ST. CT. 6.0. Of ILA. - MIAMI (b) Comb &Residence &Pi

cuments are subject to confidentiality provisions, which the federal court recognized and enforced when it permitted disclosure to the attorneys for Jane Doe 1 and Jane Doe 2 and to any other victims and their counsel, provided they not disclose the terms to anyone else. Disclosure violates a condition of t

OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. SECOND AMENDED COMPLAINT Plaintiff, Janc Doe No. 2 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe No. 2 is a c

act, and Jane Doe was thereby put in such imminent apprehension. 17. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane Doe, creating a reasonable fear of imminent peril. 18. Epstein intentionally inflicted harmful or offensive contact on the person of Jane Doe, with th

tted willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 26. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had

cution agreement and the release of material protected by Rule 6(e), both of which are remedies which the plaintiffs have said they are seeking. See Jane Doe #1 and Jane Doe #2's Response to Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction, Doc. 127 at 14. If plaintiffs still

n in a recent pleading, see Doc 381, the identity of each of the Jane Does has been known to Mr. Epstein for many years in part as a result of each Jane Doe's decision to delay the litigation of their CVRA claims in order to prioritize their parallel monetary damage lawsuits against Mr. Epstein during whi

385 Entered on FLSD Docket 04/22/2016 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs I. UNITED STATES OF AMERICA, Defendant / INTERVENOR JEFFREY EPSTEIN'S MEMORANDUM IN SUPPORT OF HIS ATTENDANCE AT

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

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

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

14. If Jane Doe was having intercourse and oral sex with other males at the time she was allegedly going to Epstein's house, this would suggest that Jane Doc understood sex and sexuality and drew specific boundaries about what she would and would not do with Epstein. 32. It also contradicts Dr. Reed's o

93 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S MOTION PURSUANT TO FED. IL EVID. 412(c1 TO ADMIT EVIDENCE OF JANE DOE'S AND OTHER WITNESSES' SEXUAL HISTORY AND INCORPORATED MOTION FOR LEAVE TO FILE SUPPLEMENTAL MOTION PURSUANT TO RULE 412(0 REGARDING OTHER WITNESSES

regarding Jane Doe being sexually inexperienced Taira the frequency of sex with and the types of and naive, making her t " victim." Evidence of Jane Doe's relationship with demonstrates that Jane Doe sex they had. eventually became sexually experienced yet continued to go to Epstein's house. To con

tirt & P.A. 1820513ismne Boulevard B.B. Susie 2218 4 Plaintiff Miami, Phone S 1, 6 ws- VOLUME al OF IV 7 8 Oa behalf of the Plaintiff, Jame Doe No. IL ISIDRO MAKIJEI. GARCIA, ESQUIRE GARCIA, MAINS& BOO-RINGER 9 224 Dan Awnuo Suite 90) West 33401 Dcfaxlinta. 10 tilde Phan( 9 11 in

m what they did with the 14 $200 they received? 15 A. I might have. I can't recall at this time if 16 I did or didn't. 17 Q. Did you ever ask lane Doe 103 — strike that. 18 • • Jane Doe I.03 told you that she had received a 19 significant amount of money because she said she bad 20 • gone to

tein would ask them to take off all 23 BY MR. WEINBERG: • 23 thek clothes, and they would take off as much clothes 24 • Q. Page 9 on So Ms. Jane Doe 4's 24 as they felt comfortable with and we re not forced to 25 . aaffidavit. date of birth is and she was 18 at the time of 25 take off

rse inference would be wholly unreliable and is clearly impermissible under the instant circumstances. Additionally, granting the relief sought by Jane Doc based solely on an adverse inference would violate Epstein's Fifth Amendment rights. LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 389 (7th Cir.

in Opposition to Jane Doe's Injunction Motion Page 22 of 24 V. CONCLUSION For the foregoing reasons, Epstein respectfully requests the Court deny Jane Doe's Injunction Motion. By: ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 DAVID A. YAREMA, ESQ. Flo

ane Doe's Request for Admissions attached as Exhibit C to Injunction Motion (DE #165). Based on this unsupported presumption of fraudulent transfer, Jane Doe asks the Court to impose significant and unjustified restraints on Epstein's assets. Simply put, Jane Doe is improperly seeking assurance she will b

for Extension of Time to File Response/Reply to Defendant's Motions for Summary Judgment (Jane Doe 2, DE 539; Jane Doe 3 DE 141; Jane Doe 4, DE 157; Jane Doe 5, DE 139; Jane Doe 6, DE 91; Jane Doe 7, DE 107) by Jane Doe. (Attachments: # 1 Text of Proposed Order)(Horowitz, Adam) (Entered: 06/01/2010) 554 O

Declarations of Jane Doe No. 4 and Y.B. in Further Support of Plaintiffs' Jane Does 2-7 Motion for Protective Order (Attachments: # 1 Declaration of Jane Doe 4, # 2 Declaration of Y.B.)(Mermelstein. Stuart) (Entered: 08/14/2009) 268 Sealed Document (rb) (Entered: 08/14/2009) 269 Unopposed MOTION for Exte

Entered: 07/06/2009) 189 ORDER granting 186 Motion for Extension of Time to Reply. Defendant has until July 14, 2009 to file a Reply to Plaintiffs Jane Doe's 2-7 Response to Defendant's Motion to Compel Identity.. Signed by Judge Kenneth A. Marra on 7/6/2009. (mkz) (Entered: 07/06/2009) Set/Reset Deadlin

Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. West Palm Beach, FL 33401-5012 Counsel for Defendant Jeffrey Epstein EFTA00599332 Jane Dee v. Etal12 Case No. 08-CV-80119-MARRA/JOHNSON Epstein's Response to Jane Doe's Motion to Provide Recently Obtained Affidavit of Epstein Page 9 of 9

80-MARRA/JOHNSON CASE NO.: 08-CV-80381-M.ARRA/JOHNSON EFTA00599325 Jane Doe v. Epstein Case No. 08-CV-80119-MARRA/JOHNSON Epstein's Response to Jane Doe's Motion to Provide Recently Obtained Affidavit of Epstein Page 2 of 9 JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. JANE DOE NO. 7, Pl

OR APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN Defendant, JEFFREY E. EPSTEIN ("Epstein"), submits this response to Plaintiff's, Jane Doe ("Jane Doe"), Motion to Provide Recently-Obtained Affidavit of Jeffrey E. Epstein in EFTA00599327 Jane Doe v. Epstein Case No. 08-CV-80119-MARRA/

essage and told her to sit on top of him. Out of fear and trepidation she complied As Jane rubbed Epstein's chest Epstein began to use a vibrator on Jane Doe's vagina. Thereafter Epstein began to digitally stimulate and attempt to penetrate Jane Doe's vagina. Ai tits same time, with his other hand, Epstein

ith a vibrator, or digitally penetrating the girl's vagina. 14. Consistent will the foregoing plan, scheme, and/or enterprise, Ms. Robson recruited Jane Doc to give Epstein a massage for monetary compensation. Ms. Robson brought Jane Doe to Epstein's mansion in Palm Beach. Jane was introduced to Sarah Ke

15151 Date 5129/200812.09:; A IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA JANE DOE, by and through JANE DOE'S MOTHER as parent and natural guardian, • Plaintiffs, V . JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, Defendants, 962118 a 0 065 9 6,0000

AM Document 56 Entered on FLSD Docket 04/07/2011 Page 2 of 19 Non-Prosecution Agreement reached between the U.S. Attorney's Office and Mr. Epstein. Jane Doe 1 and Jane Doc 2 also seek other unspecified relief, which they call "appropriate remedies," for the government's purported failure to keep them invol

d by the government arc subject to a protective order prohibiting their disclosure. In the related case 9:08-CV-80893 (the case where Jane Doe I and Jane Doe 2 sued Mr. Epstein for money), the Magistrate Judge prohibited Jane Doe 1 and Jane Doe 2 EFTA00177187 Case 9:08-cv-80736-KAM Document 56 Entered on

. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, 1. UNITED STATES OF AMERICA, Defendant. NOTICE OF' OBJECTION Petitioners Jane Doe 1 and Jane Doe 2 have moved for disclosure of settlement letters between the U.S. Attorney's Office and the lawyers who represented Jeffrey Epstein du

act, and Jane Doe was thereby put in such imminent apprehension. 17. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane Poe, creating a reasonable fear of imminent peril. 18. Epstein intentionally inflicted harmful or offensive contact on the person &Jane Doe, with the

tted willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 26. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had

Local Rule 2090-1(A). SHAPIRO LAW By: /s/ Peter E. Shapiro Peter E. Shapiro (FBN [email protected] Attorneys for Intervenors E.W., and Jane Doe 2 EFTA00793665 Case 09-34791-RBR Doc 6495 Filed 10/24/18 Page 3 of 4 SERVICE LIST Bradley J. Edwards FLB~ Brittany N. Henderson FLBN 118247 Ed

rolawpa.com Attorneys for Intervenors E.W., and Jane Doe 2 EFTA00793665 Case 09-34791-RBR Doc 6495 F

OR APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN Defendant, JEFFREY E. EPSTEIN ("Epstein"), submits this response to Plaintiff's, Jane Doe ("Jane Doe"), Motion to Provide Recently-Obtained Affidavit of Jeffrey E. Epstein in EFTA00599345 Jane Doe v. Epstein Case No. 08-CV-80119-MARRA/

80-MARRA/JOHNSON CASE NO.: 08-CV-80381-M.ARRA/JOHNSON EFTA00599343 Jane Doe v. Epstein Case No. 08-CV-80119-MARRA/JOHNSON Epstein's Response to Jane Doe's Motion to Provide Recently Obtained Affidavit of Epstein Page 2 of 9 CASE NO.: 08-80994-C1V-MARRA/JOHNSON JANE DOE NO. 6, Plaintiff, JEFFREY EPS

us conduct would cause emotional trauma and damage to Jane Doe. 24. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiff Jane Doe No. 2 demands judgment against Defendant Jef

turned executed" as the proper Event. (Ik) (Entered: 05/27/2008) 05/29/2008 2 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doc. (Attachments: #J, Exhibit A and B, #2 Text of Proposed Order Default Ord)(Horowitz, Adam) (Entered: 05/29/2008) 06/06/2008 8 CLERK'S NOTICE Denyi