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U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE #: 9:08-cv-80381-KAM 
Doe No. 5'. Epstein 
Assigned to: Judge Kenneth A. Marra 
Lead case: 9:08-cv-80119-KAM 
Member case: (View Member Case] 
Case: 9:09-cv-80802-KAM 
Cause: 28:1332 Diversity 
Plaintiff 
Jane Doe No. 5 
Date Filed: 04/14/2008 
Jury Demand: Plaintiff 
Nature of Suit: 360 P.I.: Other 
Jurisdiction: Diversity 
represented by Adam D. Horowitz 
Mermelstein & Horowitz PA 
18205 Biscayne Boulevard 
Suite 2218 
Miami FL 33160 
Fax: 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Jeffrey Marc Herman 
Herman & Mermelstein 
18205 Biscayne Boulevard 
Suite 2218 
Miami FL 33160 
Fax: 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Stuart S. Mermelstein 
Mermelstein & Horowitz PA 
18205 Biscayne Boulevard 
Suite 2218 
Miami FL 33160 
Fax: 931-0877 
Email: 
LEAD ATTORNEY 
LRJ 
https://ecf.ftsd.uscourts.gov/cgi-bin/DktRpt.pl?302073795169544-L_801_0-1 
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ATTORNEY TO BE NOTICED 
Defendant 
Jeffrey Epstein 
AJWCUS
United States of America 
represented by Jack Alan Goldberger 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach , FL 33401-5012 
Email: 
ATTORNEY TO BE NOTICED 
Michael James Pike 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Michael Ross Tein 
Lewis Tein 
3059 Grand Avenue 
Suite 340 
Coconut Grove , FL 33133 
Robert Deweese Critton , Jr. 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Fax: 
Email: 
ATTORNEY TO BE NOTICED 
represented by M
ein 
I. 
Unit 
States Attorney's Office 
500 East Broward Blvd 
7th Floor 
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Ft Lauderdale , FL 33394 
ext. 3546 
Fax:U 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Date Filed 
# 
Docket Text 
04/14/2008 
1 COMPLAINT against Jeffrey Epstein Filing fee $ 350. Receipt#: 542770, 
filed by Jane Doe No. 5.(dj) (Entered: 04/15/2008) 
04/14/2008 
2 Summons Issued as to Jeffrey Epstein. (dj) (Entered: 04/15/2008) 
04/17/2008 
3 Order Requiring Counsel to Confer and File Joint Scheduling Report.Signed 
by Judge Kenneth A. Marra on 4/16/08.(ir) (Entered: 04/17/2008) 
05/22/2008 
4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey 
Epstein on May 7, 2008, filed by Jane Doe No. 5. (Herman, Jeffrey) (Entered: 
05/22/2008) 
05/29/2008 
5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane 
Doe No. 5. (Attachments: # I Exhibit A and B, # 2 Text of Proposed Order 
Default Order)(Horowitz, Adam) (Entered: 05/29/2008) 
06/02/2008 
6 Clerks Entry of Default as to Jeffrey Epstein terminated 5 Motion for Entry of 
Default by Clerk (ail) (Entered: 06/02/2008) 
06/05/2008 
7 Plaintiffs MOTION for Judgment Upon Default and Order Setting Hearing 
on Damages by Jane Doe No. 5. (Attachments: # 1 Text of Proposed Order) 
(Horowitz, Adam) (Entered: 06/05/2008) 
06/13/2008 
I 
NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of 
Jeffrey Epstein (Goldberger, Jack) (Entered: 06/13/2008) 
06/13/2008 
2 MOTION to Set Aside Clerk's Default by Jeffrey Epstein. (Attachments: # I 
Affidavit of Richard Bamett)(Goldberger, Jack) (Entered: 06/13/2008) 
06/19/2008 
10 RESPONSE in Opposition re 7 Plaintiffs MOTION for Judgment Upon 
Default and Order Setting Hearing on Damages (DE #7) filed by Jeffrey 
Epstein. (Goldberger, Jack) (Entered: 06/19/2008) 
06/20/2008 
II Defendant's MOTION to Stay by Jeffrey Epstein. Responses due by 7/10/2008 
(Goldberger, Jack) (Entered: 06/20/2008) 
06/20/2008 
12 Defendant's MOTION for Extension of Time to File Answer or Otherwise 
Respond To Complaint by Jeffrey Epstein. (Goldberger, Jack) (Entered: 
06/20/2008) 
06/25/2008 
13 MEMORANDUM in Support re 7 Plaintiffs MOTION for Judgment Upon 
Default and Order Setting Hearing on Damages filed by Jane Doe No. 5. 
(Herman, Jeffrey) (Entered: 06/25/2008) 
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06/25/2008 
14 RESPONSE to Motion re 2 MOTION to Set Aside Clerk's Default filed by 
Jane Doe No. 5. Replies due by 7/7/2008. (Herman, Jeffrey) (Entered: 
06/25/2008) 
07/01/2008 
15 NOTICE by Jeffrey Epstein Concerning Motion To Stay [DE 11] 
(Attachments: # 1 Exhibit "A" Final Disposition Sheets)(Goldberger, Jack) 
(Entered: 07/01/2008) 
07/07/200s 
1.6 NOTICE of Attorney Appearance by Michael Ross Tein on behalf of Jeffrey 
Epstein (Tein, Michael) (Entered: 07/07/2008) 
07/07/2008 
17 MOTION Epstein's Reply in Support of Motion [DE9] to Set Asside Clerk's 
Default by Jeffrey Epstein. (Tein, Michael) (Entered: 07/07/2008) 
07/08/2008 
1.8 RESPONSE in Support re 9 MOTION to Set Aside Clerk's Default filed by 
Jeffrey Epstein. (Goldberger, Jack) (Entered: 07/08/2008) 
07/08/2008 
12 NOTICE by Jeffrey Epstein re la Response in Support of Motion [DE 9] To 
Set Aside Clerk's Default (Goldberger, Jack) (Entered: 07/08/2008) 
07/08/2008 
20 NOTICE of Instruction to Filer: re 12 MOTION Epstein's Reply in Support of 
Motion [DE9] to Set Asside Clerk's Default filed by Jeffrey Epstein Error: 
Wrong Event Selected; Instruction to Filer: Counsel is instructed to re-file 
document using the correct event REPLY TO RESPONSE TO MOTION; In 
the future please select the proper event. (dg) (Entered: 07/08/2008) 
07/08/2008 
21 REPLY to Response to Motion re 17 MOTION Epstein's Reply in Support of 
Motion [DE9] to Set Asside Clerk's Default, 2 MOTION to Set Aside Clerk's 
Default Epstein's Reply in Support of Motion [DE9] to Set Aside Clerk's 
Default filed by Jeffrey Epstein. (Tein, Michael) (Entered: 07/08/2008) 
07/10/2008 
22 Plaintiffs MOTION for Extension of Time to File Response as to 11 
Defendant's MOTION to Stay by Jane Doe No. 5. (Attachments: # 1 Text of 
Proposed OrderXHorowitz, Adam) (Entered: 07/10/2008) 
07/10/2008 
23 Sealed Document. (ye) UNSEALED see DE 27 .Modified on 7/17/2008 (tb). 
(Entered: 07/10/2008) 
07/10/2008 
24 Sealed Document. (yc)UNSEALED see DE 28 . Modified on 7/17/2008 (tb). 
(Entered: 07/10/2008) 
07/10/2008 
2/ UNSEALED MOTION to seal by Jeffrey Epstein.(previously filed as 23 
sealed document) (tb) (Entered: 07/17/2008) 
07/10/2008 
2_a UNSEALED Notice of Continued Pendency of Federal Criminal Action by 
Jeffrey Epstein (previously filed as 24 sealed document) (tb) (Entered: 
07/17/2008) 
07/16/2008 
25 ORDER denying motion to file Ex Parte and Under Seal. The Clerk shall 
unseal DE 23 and 24 and make them available for public inspection through 
CM/ECF at the earliest possible time. Signed by Judge Kenneth A. Marra on 
7/16/08. (ir) (Additional attachments) added on 7/17/2008: # 1 docket sheet) 
(tb). (Entered: 07/16/2008) 
07/16/2008 
2.6 OPINION AND ORDER denying without prejudice 2 Motion to Set Aside 
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Default. The Defendant has ten days to file a second motion to vacate the 
default. Signed by Judge Kenneth A. Marra on 7/16/08. (ir) (Entered: 
07/16/2008) 
07/18/2008 
22 RESPONSE to Motion re 11 Defendant's MOTION to Stay and Memorandum 
of Law filed by Jane Doe No. 5. Replies due by 7/28/2008. (Attachments: # 1 
Exhibit A)(Herman, Jeffrey) (Entered: 07/18/2008) 
07/21/2008 
3Q
AFFIDAVIT signed by : Jeffrey M. Herman. Regarding Service of Process 
and this Court's Order to Show Cause by Jane Doe No. 5. (Herman, Jeffrey) 
(Entered: 07/21/2008) 
07/25/2008 
31 
MOTION for Hearing Defendant's Request for Oral Argument by Jeffrey 
Epstein. (Tein, Michael) (Entered: 07/25/2008) 
07/25/2008 
32 ORDER vacating 26 Order on Motion to Set Aside, vacating 6 Clerks Entry of 
Default filed by Jeffrey Epstein, granting 2 MOTION to Set Aside Clerk's 
Default filed by Jeffrey Epstein. Signed by Judge Kenneth A. Marra on 
7/25/08. (ir) (Entered: 07/25/2008) 
07/28/2008 
33 UNSEALED Sealed Document. (tas) Modified on 8/12/2008 **Please see DE 
# 41 for Image** (gp). (Entered: 07/28/2008) 
07/28/2008 
34 
UNSEALED Sealed Document. (tas) Modified on 8/12/2008 **Please see DE 
# 42 for Image** (gp). (Entered: 07/28/2008) 
07/28/2008 
•11 
UNSEALED MOTION for Leave to File by Jeffrey Epstein. {Originally DE # 
33 } (gp) (Entered: 08/12/2008) 
07/28/2008 
1 
UNSEALED REPLY to Response to Motion re U Defendant's MOTION to 
Stay filed by Jeffrey Epstein. (Originally DE # 34 } (gp) (Entered: 
08/12/2008) 
07/29/2008 
35 NOTICE by Jeffrey Epstein Defendant's Notice of Filing Exhibits 
(Attachments: # 1 Exhibit A, # 2 Exhibit B)(Tein, Michael) (Entered: 
07/29/2008) 
. 
• 
07/30/2008 
16 NOTICE by Jeffrey Epstein Waiver of Service (Tein, Michael) (Entered: 
07/30/2008) 
08/05/2008 
37 ORDER DENYING MOTION TO SEAL. The Clerk shall unseal DE 33 
Sealed Document, 34 Sealed Document and make them available for public 
inspection through CM/ECF. Signed by Judge Kenneth A. Marra on 8/4/08. 
(ir) (Entered: 08/05/2008) 
08/05/2008 
3$ ORDER denying 11 Motion to Stay; granting nunc pro tunc 22 Motion for 
Extension of Time to Respond ; denying as moot 31 Motion for Hearing. 
Signed by Judge Kenneth A. Marra on 8/4/08. (ir) (Entered: 08/05/2008) 
08/06/2008 
39 Joint MOTION to Approve Stipulation for Acceptance of Service of Process 
and Agreed Date for Defendant's Responses to Complaints by Jane Doe No. 5. 
(Attachments: #1 Stipulation, # 2 Text of Proposed Order Approving 
Stipulation)(Herman, Jeffrey) (Entered: 08/06/2008) 
08/07/2008 
40 ENDORSED ORDER granting 32 Motion to Approve Stipulation for 
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Acceptance of Service of Process and Agreed Date for Defendant's Responses 
to Complaints. Signed by Judge Kenneth A. Marra on 8/6/08. (ir) (Entered: 
08/07/2008) 
08/07/2008 
Reset Answer Due Deadline: Jeffrey Epstein response due 9/4/2008. (ir) 
(Entered: 08/07/2008) 
08/27/2008 
41 NOTICE by Jeffrey Epstein Notice of Appearance (Pike, Michael) (Entered: 
08/27/2008) 
08/28/2008 
Clerks Notice of Docket Correction and Instruction to Filer re 43 Notice 
(Other) filed by Jeffrey Epstein. Error - Wrong Event Selected; Correction - 
Redocketed by Clerk as NOTICE of Attorney Appearance. Instruction to Filer 
- In the future, please select the proper event. It is not necessary to refile this 
document. (ail) (Entered: 08/28/2008) 
08/28/2008 
44 NOTICE of Attorney Appearance by Michael James Pike, Robert Deweese 
Critton, Jr on behalf of Jeffrey Epstein (ail) (Entered: 08/28/2008) 
09/04/2008 
45 Defendant's MOTION to Dismiss 1 Complaint by Jeffrey Epstein. Responses 
due by 9/22/2008 (Tein, Michael) (Entered: 09/04/2008) 
09/22/2008 
46 MEMORANDUM in Opposition re 45 Defendant's MOTION to Dismiss 1 
Complaint filed by Jane Doe No. 5. (Herman, Jeffrey) (Entered: 09/22/2008) 
09/22/2008 
47 AMENDED COMPLAINT, filed by Jane Doe No. 5.(Herman, Jeffrey) 
(Entered: 09/22/2008) 
09/23/2008 
48 ENDORSED ORDER denying as moot 2 Motion for Judgment upon Default. 
Clerk's entry of default vacated on 7/25/08. See DE 32. Signed by Judge 
Kenneth A. Marra on 9/23/08. (ir) (Entered: 09/23/2008) 
09/23/2008 
42 ORDER denying as moot 4.5 Motion to Dismiss; denying as moot 12 Motion 
for Extension of Time to Respond to Complaint. Signed by Judge Kenneth A. 
Marra on 9/23/08. (ir) (Entered: 09/23/2008) 
09/25/2008 
51). SCHEDULING REPORT- Rule 26(1). (Herman, Jeffrey) (Entered: 
09/25/2008) 
09/30/2008 
51. SCHEDULING ORDER: Jury Trial set for 1/25/2010 09:00 AM in West 
Palm Beach Division before Judge Kenneth A. Marra. Calendar Call set for 
1/22/2010 10:00 AM in West Palm Beach Division before Judge Kenneth A. 
Marra., Amended Pleadings due by 12/1/2008. Discovery due by 8/3/2009. 
Motions due by 8/31/2009. ORDER REFERRING CASE to Magistrate Judge 
Linnea R. Johnson for Discovery Proceedings, ORDER REFERRING CASE 
to Mediation. 15 days to appoint mediator. Signed by Judge Kenneth A. Marra 
on 9/29/08. (ir) (Entered: 09/30/2008) 
10/06/2008 
52 Defendant's MOTION to Dismiss 42 Amended Complaint and for More 
Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Critton, 
Robert) (Entered: 10/06/2008) 
10/24/2008 
53 Unopposed MOTION for Extension of Time to File Response as to 52 
Defendant's MOTION to Dismiss 42 Amended Complaint and for More 
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Definite Statement by Jane Doe No. 5. (Attachments: # 1 Text of Proposed 
Order)(Herman, Jeffrey) (Entered: 10/24/2008) 
10/27/2008 
54 ORDER granting (47 in 9:08-cv-80119-ICAM) Unopposed MOTION for 
Extension of Time to File Response as to (46) Defendant's MOTION to 
Dismiss (42) Amended Complaint and for More Definite Statement 
( Responses due by 10/31/2008) in case 9:08-cv-80119-KAM; granting (43) 
Motion for Extension of Time to Respond re (47 in 9:08-cv-80119-ICAM) 
Unopposed MOTION for Extension of Time to File Response as to (46) 
Defendant's MOTION to Dismiss (42) Amended Complaint and for More 
Definite Statement in case 9:08-cv-80232-KAM; granting (55) Motion for 
Extension of Time to Respond re (47 in 9:08-cv-80119-ICAM) Unopposed 
MOTION for Extension of Time to File Response as to (46) Defendant's 
MOTION to Dismiss (42) Amended Complaint and for More Definite 
Statement in case 9:08-cv-80380-ICAM; granting (53) Motion for Extension of 
Time to Respond re (47 in 9:08-cv-80119-KAM) Unopposed MOTION for 
Extension of Time to File Response as to (46) Defendant's MOTION to 
Dismiss (42) Amended Complaint and for More Definite Statement in case 
9:08-cv-80381-KAM in case 9:08-cv-80119-KAM. Signed by Judge Kenneth 
A. Marra on 10/24/2008. (ir) (Entered: 10/27/2008) 
10/28/2008 
Reset Deadlines as to Defendant's MOTION to Dismiss (49) Amended 
Complaint and for More Definite Statement. Responses due by 10/31/2008. 
(ir) (Entered: 10/28/2008) 
10/31/2008 
55 MEMORANDUM in Opposition re 52 Defendant's MOTION to Dismiss ‘17 
Amended Complaint and for More Definite Statement filed by Jane Doe No. 
5. (Attachments: # 1 Exhibit A)(Herman, Jeffrey) (Entered: 10/31/2008) 
11/10/2008 
56 RESPONSE/REPLY to 55 Memorandum in Opposition to Defendant's Motion 
►o Dismiss filed by Jeffrey Epstein. (Critton, Robert) (Entered: 11/10/2008) 
12/30/2008 
51 NOTICE by Jeffrey Epstein of Withdrawal as Co-Counsel (rein, Michael) 
(Entered: 12/30/2008) 
02/12/2009 
5 OPINION AND ORDER granting in part and denying in part 52 Motion to 
Dismiss. Signed by Judge Kenneth A. Marra on 2/12/2009. (ir) (Entered: 
02/12/2009) 
02/23/2009 
59 NOTICE by Jane Doe No. 5 of Change of Name of Plaintiffs Counsel 
(Horowitz, Adam) (Entered: 02/23/2009) 
02/27/2009 
5Q AMENDED COMPLAINT (Second), filed by Jane Doe No. 5.(Horowitz, 
Adam) (Entered: 02/27/2009) 
03/02/2009 
61 Plaintiff's MOTION to Compel Answers to Interrogatories and Production of 
Documents and Incorporated Memorandum of Law in Support by Jane Doe 
No. 5. Responses due by 3/19/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit 
B)(Horowitz, Adam) (Entered: 03/02/2009) 
03/04/2009 
62 Defendant's MOTION for Extension of Time to File Response as to 6Q 
Amended Complaint with proposed Order by Jeffrey Epstein. (Critton, 
Robert) (Entered: 03/04/2009) 
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03/05/2009 
63 ENDORSED ORDER granting 62 Motion for Extension of Time to Answer 
Complaint. Jeffrey Epstein response due 4/3/2009. Signed by Judge Kenneth 
A. Marra on 3/5/2009. (ir) (Entered: 03/05/2009) 
03/06/2009 
64 Defendant's MOTION for Extension of Time to File Response as to 61 
Plaintiffs MOTION to Compel Answers to Interrogatories and Production of 
Documents and Incorporated Memorandum of Law in Support with proposed 
Order by Jeffrey Epstein. (Critton, Robert) (Entered: 03/06/2009) 
03/18/2009 
65 Defendant's MOTION for Leave to File Excess Pages with proposed Order in 
Response to 61 Motion to Compel Answers and Interrogatories and 
Production of Documents, Including Supporting Memorandum of Law by 
Jeffrey Epstein. (Critton, Robert) Modified link and text on 3/19/2009 (tas). 
(Entered: 03/18/2009) 
03/19/2009 
66 Clerks Notice of Docket Correction and Instruction to Filer re 65 Defendant's 
MOTION for Leave to File Excess Pages with proposed Order filed by Jeffrey 
Epstein. Error - Incorrect Document Link/No Link; Correction - Document 
refitted properly by Clerk. Instruction to filer - In the future, please link the 
document to the proper entry. It is not necessary to refile this document. (tas) 
(Entered: 03/19/2009) 
03/25/2009 
67 RESPONSE to Motion re 61 Plaintiffs MOTION to Compel Answers to 
Interrogatories and Production of Documents and Incorporated Memorandum 
of Law in Support filed by Jeffrey Epstein. Replies duel:a 4/6/2009. 
(Attachments: # I Exhibit A, # 2 Exhibit B, # 3 Exhibit I)(Critton, Robert) 
(Entered: 03/25/2009) 
03/25/2009 
61 Defendant's MOTION to Stay re fiQ Amended Complaint by Jeffrey Epstein. 
Respon s due by 4/13/2009 (Attachments: #1 Exhibit A, # 2 Exhibit B, # a 
Exhibit t(Pike, Michael) (Entered: 03/25/2009) 
04/02/2009 
e 
Defendant's MOTION to Compel Respnse to I st RTP by Jeffrey Epstein. 
Responses due by 4/20/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # a 
Exhibit 
# 4 Exhibit D)(Critton, Robert) (Entered: 04/02/2009) 
04/02/2009 
ZQ Defendant's MOTION to Compel Answers to 1st Interrogs by Jeffrey Epstein. 
Responses due by 4/20/2009 (Attachments: # I Exhibit A, # 2 Exhibit B, # a 
Exhibit t(Critton, Robert) (Entered: 04/02/2009)
04/02/2009 
n Defendant's ANSWER and Affirmative Defenses to Amended Complaint 
(Second) by Jeffrey Epstein.(Critton, Robert) (Entered: 04/02/2009) 
04/03/2009 
22
Unopposed MOTION for Extension of Time to File Reply as to 61 Response 
to Motion, to Compel Answers to Interrogatories and Production of 
Documents by Jane Doe No. 5. (Attachments: # 1 Text of Proposed Order) 
(Mermelstein, Stuart) (Entered: 04/03/2009) 
04/13/2009 
73 Unopposed MOTION for Extension of Time to File Response /Memorandum 
in Opposition to Motion to Stay and/or Continue Action by Jane Doe No. 5. 
(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 
04/13/2009) 
04/14/2009 
74 ENDORSED ORDER granting (75) Motion for Extension of Time to Respond 
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re (65 in 9:08-cv-80119-ICAM) Defendant's MOTION to Stay re (56) 
Amended Complaint in case 9:08-cv-80119-KAM; granting (67) Motion for 
Extension of Time to Respond re (65 in 9:08-cv-80119-ICAM) Defendant's 
MOTION to Stay re (56) Amended Complaint in case 9:08-cv-80232-KAM; 
granting (82) Motion for Extension of Time to Respond re (65 in 9:08-cv-
80119-KAM) Defendant's MOTION to Stay re (56) Amended Complaint in 
case 9:08-cv-80380-KAM; granting (73) Motion for Extension of Time to 
Respond re (65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56) 
Amended Complaint in case 9:08-cv-80381-1CAM; granting (33) Motion for 
Extension of Time to Respond re (65 in 9:08-cv-80119-KAM) Defendant's 
MOTION to Stay re (56) Amended Complaint in case 9:08-cv-80993-KAM; 
granting (27) Motion for Extension of Time to Respond re (65 in 9:08-cv-
80119-1CAM) Defendant's MOTION to Stay re (56) Amended Complaint in 
case 9:08-cv-80994-KAM in case 9:08-cv-80119-ICAM. ( Responses due by 
4/23/2009). Signed by Judge Kenneth A. Marra on 4/14/2009. (ir) (Entered: 
04/14/2009) 
04/17/2009 
75 Unopposed MOTION for Extension of Time to File Response as to 70 
Defendant's MOTION to Compel Answers to 1st Interrogs, 62 Defendant's 
MOTION to Compel Respnse to 1st RTP by Jane Doe No. 5. (Attachments: # 
1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 04/17/2009) 
04/20/2009 
76 MEMORANDUM in Support re 61 Plaintiffs MOTION to Compel Answers 
to Interrogatories and Production of Documents and Incorporated 
Memorandum of Law in Support by Jane Doe No. 5. (Mermelstein, Stuart) 
(Entered: 04/20/2009) 
04/23/2009 
77 RESPONSE in Opposition re a Defendant's MOTION to Stay re 0.0 
Amended Complaint filed by Jane Doe No. 5. (Mermelstein, Stuart) (Entered: 
04/23/2009) 
04/28/2009 
78 ORDER TO SHOW CAUSE why cases should not be consolidated for 
discovery purposes Show Cause Response due by 5/5/2009.. Signed by Judge 
Kenneth A. Marra on 4/28/2009. (cqs) (Entered: 04/29/2009) 
04/29/2009 
72 Unopposed MOTION for Extension of Time to File Response as to 70 
Defendant's MOTION to Compel Answers to 1st Interrogs, 62 Defendant's 
MOTION to Compel Respnse to 1st RTP by Jane Doe No. 5. (Attachments: # 
1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 04/29/2009) 
05/04/2009 
Q MEMORANDUM in Opposition re 71 Order to Show Cause by Jeffrey 
Epstein. (Pike, Michael) (Entered: 05/04/2009) 
05/05/2009 
II RESPONSE TO ORDER TO SHOW CAUSE by Jane Doe No. 5. 
(Mermelstein, Stuart) (Entered: 05/05/2009) 
05/05/2009 
82 Defendant's MOTION for Extension of Time to File Reply as to 72 Response 
in Opposition to Motion to Stay by Jeffrey Epstein. (Pike, Michael) (Entered: 
05/05/2009) 
05/06/2009 
83 ENDORSED ORDER granting (89) Motion for Extension of Time to Reply re 
(65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56) Amended 
Complaint; granting (81) Motion for Extension of Time to Reply re (65 in 
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9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56) Amended 
Complaint in case 9:08-cv-80232-KAM; granting (97) Motion for Extension 
of Time to Reply re (65 in 9:08-cv-80119-KAM) Defendant's MOTION to 
Stay re (56) Amended Complaint in case 9:08-cv-80380-KAM; granting (82) 
Motion for Extension of Time to Reply re (65 in 9:08-cv-80119-ICAM) 
Defendant's MOTION to Stay re (56) Amended Complaint in case 9:08-cv-
80381-1CAM; granting (46) Motion for Extension of Time to Reply re (65 in 
9:08-cv-80119-ICAM) Defendant's MOTION to Stay re (56) Amended 
Complaint in case 9:08-cv-80993-KAM; granting (37) Motion for Extension 
of Time to Reply re (65 in 9:08-cv-80119-1CAM) Defendant's MOTION to 
Stay re (56) Amended Complaint in case 9:08-cv-80994-KAM in case 9:08-
cv-80119-KAM. ( Replies due by 5/20/2009.). Signed by Judge Kenneth A. 
Marra on 5/5/2009. (ir) (Entered: 05/06/2009) 
05/06/2009 
81 RESPONSE in Opposition re 71) Defendant's MOTION to Compel Answers to 
1st Interrogs and for an Award of Reasonable Expenses filed by Jane Doe No. 
5. (Horowitz, Adam) (Entered: 05/06/2009) 
05/06/2009 
t 
RESPONSE in Opposition re 69 Defendant's MOTION to Compel Respnse to 
1st RTP , Overrule Objections and for an Award of Reasonable Expenses filed 
by Jane Doe No. 5. (Attachments: # 1 Exhibit A)(Horowitz, Adam) (Entered: 
05/06/2009) 
05/06/2009 
86 Defendant's MOTION to Compel Identity of Doe #5 in Style of ase and 
Third-Party Subpoenas by Jeffrey Epstein. Responses due by 5/26/2009 
(Attachments: # 1 Exhibit A)(Pike, Michael) (Entered: 05/06/2009) 
05/11/2009 
Sii Defendant's MOTION for Order requiring that plaintiff use Proper Case Style 
in all Filings by Jeffrey Epstein. (Critton, Robert) Modified on 5/13/2009 (Is). 
[Text modified by Clerk] (Entered: 05/11/2009) 
05/13/2009 
88 Clerks Notice of Docket Correction and Instruction to Filer re 82 Defendant's 
MOTION Require Plaintiff to Use Proper Case Style filed by Jeffrey Epstein. 
Error - Docket text does not match document; Correction - Docket text 
modified by Clerk. It is not necessary to refile this document. (1s) (Entered: 
05/13/2009) 
05/13/2009 
$2 RESPONSE/REPLY to 17 Response in Opposition to Motion to Stay and/or 
Continue Action by Jeffrey Epstein. (Pike, Michael) (Entered: 05/13/2009) 
05/14/2009 
Cases associated. (dg) (Entered: 05/14/2009) 
05/14/2009 
94 ORDER CONSOLIDATING CASES. Hereinafter all motions and other court 
filings that relate to discovery and all procedural motions that relate to 
multiple cases shall be styled with all of the case names and numbers and shall 
be filed in Case No. 08-80119-OV-MARRA. Signed by Judge Kenneth A. 
Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM et al. (ir) 
(Entered: 05/14/2009) 
05114/2009 
9.1. ORDER REQUESTING UNITED STATES PROVIDE POSITION TO 
MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009. 
(Attachments: # I Appendix Motion to Stay DE 51) Associated Cases: 9:08-
cv-80119-ICAM et al. (ir) (Entered: 05/14/2009) 
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92 ORDER denying as moot 81 Motion. See Order consolidating cases.. Signed 
by Judge Kenneth A. Marra on 05/15/2009. (1c3) (Entered: 05/14/2009) 
05/14/2009 
93 ORDER terminating 0 Motion to Stay; terminating 8 Motion to Compel. 
See Order consolidating cases. See procedural motions pending: DE 65 and 
DE 91 in 08-80119.. Signed by Judge Kenneth A. Marra on 5/15/2009. (1c3) 
(Entered: 05/14/2009) 
05/18/2009 
94 Defendant's MOTION for Extension of Time to File Reply as to (39 in 9:08-
cv-80994-ICAM) Response in Opposition to Motion, (40 in 9:08-cv-80994-
KAM) Response in Opposition to Motion by Jeffrey Epstein. Associated 
Cases: 9:08-cv-80119-ICAM et al.(Pike, Michael) (Entered: 05/18/2009) 
05/19/2009 
% Defendant's MOTION to Strike Cases from Current Trial Docket by Jeffrey 
Epstein. Responses due by 6/8/2009 (Attachments: # 1 Exhibit A)Associated 
Cases: 9:08-cv-80119-KAM et al.(Pike, Michael) (Entered: 05/19/2009) 
05/19/2009 
ifi MOTION for Leave to Withdraw as Co-Counsel by Jeffrey Epstein. 
(Attachments: # 1 Text of Proposed Order)(Tein, Michael) Event Modified on 
5/20/2009 (ail). (Entered: 05/19/2009) 
05/20/2009 
97 ORDER terminating (93) Motion to Strike ; terminating (94) Motion in case 
9:08-cv-80232-KAM; terminating (110) Motion to Strike ; terminating (111) 
Motion in case 9:08-cv-80380-KAM; terminating (95) Motion to Strike ; 
terminating (96) Motion in case 9.08-cv-80381-ICAM; terminating (90) 
Motion to Strike ; terminating (91) Motion in case 9:08-cv-80811-KAM; 
terminating (62) Motion to Strike in case 9:08,-cv-80893-ICAM; terminating 
(62) Motion to Strike in case 9:08-cv-80993-KAM; terminating (50) Motion 
to Strike in case 9:08-cv-80994-ICAM. Signed by Judge Kenneth A. Marra on 
5/20/2009. (1c3) (Entered: 05/20/2009) 
05/20/2009 
9B NOTICE by 
of Filing Withdrawal of Previously RaisedObjections to 
Defendant, Jeffrey Epstein's Motion to ConaitAnd/Or Identify 
. in the 
Style of This Case and Motion to IdentlfrM. in Third-Party Subpoenas 
for Purposes of Discovery, Or, Alternatively, Motion to Dismiss Sua Sponte, 
With Inorporated Memorandum of Law Associated Cases: 9:08-cv-80119-
1CAM et al.(Hill, Jack) (Entered: 05/20/2009) 
05/20/2009 
99 Clerks Notice of Docket Correction and Instruction to Filer re 2¢ MOTION 
Motion for Leave to Withdraw as Co-Counsel filed by Jeffrey Epstein. The 
Filer selected the wrong motion relief when docketing the Motion. The 
correction was made by the Clerk. It is not necessary to refile this document 
but future motions filed must include all applicable relief events. (ail) 
(Entered: 05/20/2009) 
05/20/2009 
100 ORDER STRIKING in all Epstein cases EXCEPT case no. 08-80119: Notice 
by M. 
of Filing Withdrawal of Previously Raised Objections to Epstein's 
Motion to Compel and/or Identify. This Notice should only be filed in 08-
80119, not in all of the Epstein cases.. Signed by Judge Kenneth A. Marra on 
5/20/2009. Associated Cases: 9:08-cv-80119-ICAM et al. (Ic3) (Entered: 
05/20/2009) 
05/21/2009 
101 Plaintiffs MOTION for Extension of Time to File Response as to (91 in 9:08-
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cv-80119-ICAM) Defendant's MOTION to Compel Identity of Doe in Style of 
Case and Third-Pony Subpoenas (replaces Docket entry 90) by Jane Doe No. 
6, Jane Doe No. 7, Jane Doe, Jane Doe No. 5, Jane Doe No. 4, Jane Doe No. 
3. Associated Cases: 9:08-cv-80119-ICAM et al.(Mermelstein, Stuart) 
(Entered: 05/21/2009) 
05/22/2009 
102 ORDER terminating (100) Motion for Extension of Time to Respond in case 
9:08-cv-80232-ICAM; terminating (117) Motion for Extension of Time to 
Respond in case 9:08-cv-80380-KAM; terminating (101) Motion for 
Extension of Time to Respond in case 9:08-cv-80381-KAM; terminating (67) 
Motion for Extension of Time to Respond in case 9:08-cv-80993-KAM; 
terminating (54) Motion for Extension of Time to Respond in case 9:08-cv-
80994-KAM. The attorneys are instructed again to ONLY file this type of 
motion in case no. 08-80119. See Order consolidating cases for details.. 
Signed by Judge Kenneth A. Maim on 5/22/2009. (1c3) (Entered: 05/22/2009) 
05/27/2009 
103 NOTICE by Jane Doe re (111 in 9:08-cv-80119-KAM) Plaintiffs MOTION 
for Extension of Time to File Response as to (91 in 9:08-cv-80119-ICAM) 
Defendant's MOTION to Compel Identity of Doe in Style of Case and Third-
Party Subpoenas (replaces Docket entry 90)Plaintiffs MOTION for Extension 
of Time to File Response as to (91 in 9:08-cv-80119-ICAM) Defendant's 
MOTION to Compel Identity of Doe in Style of Case and Third-Party 
Subpoenas (replaces Docket entry 90) (Attachments: # 1 Text of Proposed 
Order)Associated Cases: 9:08-cv-80119-ICAM et al.(Horovvitz, Adam) 
(Entered: 05/27/2009) 
05/28/2009 
104 ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in case 
08-80119. This Notice should only be filed in 08-80119, not in all of the 
Epstein cases... Signed by Judge Kenneth A. Marra on 5/28/2009. Associated 
Cases: 9:08-cv-80119-KAM et al. (1c3) (Entered: 05/28/2009) 
05/29/2009 
105 NOTICE of Attorney Appearance by 
. 
on behalf of 
iiii
iiiiiiiiiiiic
(aEAntsesoci.aoted5/2C9n
ase0s0:99):08-cv-80119-KAM et al. 
05/29/2009 
10 RESPONSE to Motion re (72 in 9:08-cv-80380-KAM) Defendant's MOTION 
to Stay re (62) Amended Complaint, (57 in 9:08-cv-80232-KAM) Defendant's 
MOTION to Stay re (50) Amended Complaint, (24 in 9:08-cv-80893-KAM) 
Defendant's MOTION to Stay re (1) Complaint, (23 in 9:08-cv-80994-KAM) 
Defendant's MOTION to Stay re (18) Amended Complaint, (22 in 9:08-cv-
80993-KAM) Defendants MOTION to Stay re (19) Amended Complaint, (65 
in 9:08-cv-80119-KAM) Defendants MOTION to Stay re (56) Amended 
Complaint, (68 in 9:08-cv-80381-ICAM) Defendant's MOTION to Stay re (60) 
Amended Complaint, (51 in 9:08-cv-80811-KAM) Defendant's MOTION to 
Stay it (40) Amended Complaint and or Continue Action Filed Pursuant to 
Court's Order Requesting Government's Position filed by United States of 
erica. Replies due
 6/8/2009. Associated Cases: 9:08-cv-80119-KAM et 
al. 
, 
=) 
(Entered: 05/29/2009) 
05/29/2009 
1Q2 RESPONSE in Opposition re (90 in 9:08-cv-80119-ICAM) Defendant's 
MOTION to Compel !dent& Doe in Style of Case and in Third-Party 
Subpoenas, (91 in 9:08-cv-80119-ICAM) Defendant's MOTION to Compel 
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Identity of Doe in Style of Case and Third-Party Subpoenas (replaces Docket 
entry 90) filed by Jane Doe No. 102, Jane Doe No. 101. Associated Cases: 
9:08-cv-80119-1CAM et al.(Ezell, Katherine) (Entered: 05/29/2009) 
05/29/2009 
108 ORDER STRIKING (124 in 9:08-cv-80119-ICAM, 105 in 9:08-cv-80811-
KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-ICAM, 106 in 9:08-
cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-KAM, 25 
in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-80656-
KAM, 107 in 9:08-cv-80381-ICAM) Response in Opposition to Motion, filed 
by Jane Doe No. 102, Jane Doe No. 101 DO NOT FILE IN EVERY 
EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES.. Signed by 
Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-cv-80119-
ICAM et al. (Ic3) (Entered: 05/29/2009) 
05/29/2009 
109 MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION TO 
DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIM TO 
UNSEAL THE NONPROSECUTION AGREEMENT by Jane Doe No. 102, 
Jane Doe No. 101. Associated Cases: 9:08-cv-80119-KAM et al.(Ezell, 
Katherine) (Entered: 05/29/2009) 
05/29/2009 
11.0 MOTION for Hearing MOTION TO RESCHEDULE HEARING by Jane Doe 
No. 102, Jane Doe No. 101. Associated Cases: 9:08-cv-80119-ICAM et al. 
(Josefsberg, Robert) (Entered: 05/29/2009) 
06/01/2000 
111 ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-KAM, 77 in 9:08-
cv-80993-KAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-KAM, 63 
in 9:08-cv-80994-KAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv-80811-
KAM) Motion to Continue Hearing filed by Jane Doe No. 102, Jane Doe No. 
101, (76 in 9:08-cv-80993-ICAM, 109 in 9:08-cv-80381-KAM, 108 in 9:08-
cv-80232-ICAM, 62 in 9:08-cv-80994-ICAM, 125 in 9:08-cv-80380-KAM, 74 
in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-ICAM, 37 in 9:09-cv-80591-
KAM, 107 in 9:08-cv-80811-ICAM, 27 in 9:09-cv-80469-KAM) Motion for 
Leave to File, filed by Jane Doe No. 102, Jane Doe No. 101. THESE 
DOCUMENTS SHOULD BE FILED ONLY IN 08-80119. SEE CASE 
MANAGEMENT ORDER.. Signed by Judge Kenneth A. Marra on 6/1/2009. 
(Ic3) (Entered: 06/01/2009) 
06/01/2009 
Reset Scheduling Order Deadlines: Calendar Call set for 5/28/2010 10:00 AM 
in West Palm Beach Division before Judge Kenneth A. Marra., Jury Trial set 
for 6/1/2010 09:00 AM in West Palm Beach Division before Judge Kenneth 
A. Marra., Discovery due by 12/11/2009., Dispositive Motions due by 
1/8/2010. (ir) (Entered: 06/01/2009) 
06/04/2009 
112 REPLY to Response to Motion re (113 in 9:08-cv-80119-ICAM) Plaintiffs 
MOTION Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-
Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply to 
Defendant Jeffrey Epstein's Response to Plaintiffs Jane Doe No. 101 and Jane 
Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, 
Jane Doe No. 102. Associated Cases: 9:08-cv-80119-KAM et al.(Ezell, 
Katherine) (Entered: 06/04/2009) 
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06/04/2009 
113 ORDER STRIKING (112 in 9:08-cv-80381-KAM, Ill in 9:08-cv-80232-
KAM, 136 in 9:08-cv-80119-KAM, III in 9:08-cv-80811-KAM, 128 in 9:08-
cv-80380-KAM, 65 in 9:08-cv-80994-ICAM, 79 in 9:08-cv-80893-KAM, 42 
in 9:09-cv-80591-KAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09-cv-80469-
KAM, 79 in 9:08-cv-80993-KAM) Reply to Response to Motion, filed by 
Jane Doe No. 102, Jane Doe No. 101 Document stricken for failure to follow 
Court's orders. DO NOT FILE A DOCUMENT IN EVERY EPSTEIN CASE 
if it is to be filed only in 08-80119. See Case Management Order and contact 
CM/ECF Support for assistance in proper filing.. Signed by Judge Kenneth A. 
Marra on 6/4/2009. Associated Cases: 9:08-cv-80119-ICAM et al. (1c3) 
(Entered: 06/04/2009) 
06/08/2009 
114 RESPONSE to Motion re (91 in 9:08-cv-80119-ICAM) Defendant's MOTION 
to Compel Identity of Doe In Style of Case and Third-Party Subpoenas 
(replaces Docket entry 90) filed by Jane Doe. Replies due by 6/18/2009. 
(Attachments: # 1 Exhibit A, # 2 Exhibit B)Associated Cases: 9:08-cv-80119-
KAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/08/2009 
111 NOTICE by Jane Doe re (113 in 9:08-cv-80119-ICAM) Plaintiffs MOTION 
Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-Contact Order 
-Plaintiffs Jane Does 2-7 Notice ofJoinder Associated Cases: 9:08-cv-80119-
ICAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/09/2009 
11.6 Unopposed MOTION to Amend/Correct 21 Answer to Amended Complaint 
by Jeffrey Epstein. Responses due by 6/26/2009 (Attachments: # 1 Exhibit 
"A", # 2 Exhibit "B", # 3 Text of Proposed Order Order)(Pike, Michael) 
(Entered: 06/09/2009) 
PACER Service Center 
Transaction Receipt 
06/09/2009 16:46:09 
PACER Login: du4480 
Client Code: 
Description: 
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 earch Criteria: 9: 8 
cv-80381- 
0 
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• Case 9:08-cv-E 
31-KAM 
Document 52 
Entered I FLSD Docket 10/i 
!008 
Page 1 of 10 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80381-MARRA-JOHNSON 
JANE DOE NO. 5 
Plaintiff, 
JEFFREY EPSTEIN, 
Defendant. 
DEFENDANT'S. EPSTEIN. MOTION TO DISMISS AND MOTION FOR MORE 
DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPLAINT 
Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves 
to dismiss and for more definite statement of Plaintiff JANE DOE NO. 5's Amended 
Complaint. Rules 12(b)(6), and 12(e) and (f), Fed.R.Civ.P. (2008). In support of his 
motion, Defendant states: 
Introduction 
Defendant is filing similar motions to dismiss and for more definite statement 
directed to the Amended Complaints filed against Defendant in this Court in JANE DOE 
NO. 2, JANE DOE NO. 3, JANE DOE NO. 4 and JANE DOE NO. 5. The motions are 
directed to the Counts for "Sexual Assault and Battery," and "Coercion and Enticement 
to Sexual Activity In Violation of 18-. 
§2422" in each of the respective complaints. 
However, there are distinctions in the four motions filed based on the complaint 
allegations. For example, Defendant challenges the Plaintiffs' allegations as to assault 
in all four actions, and challenges the battery allegations in JANE DOE NOS. 2 and 3, 
but not in JANE DOE NOS. 4 and 5. Defendant moves to dismiss the §2422 count in all 
four actions. 
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Document 52 
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008 
Page 2 of 10 
Case No. CV-80381-Marra-Johnson 
Page No. 2 
Motion 
1. Counts I and III of the Amended Complaint are required to be dismissed for 
failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has 
failed to allege sufficient factual allegations in the Counts and instead alleges labels and 
conclusions, and an attempted formulaic recitation of the elements in each Count. 
2. In the alternative, Defendant seeks more definite statement of Count I and III. In 
Count I, the Plaintiff is required to more definitely allege in the context of the claim for 
assault underlying factual allegations pertaining to the creation in Plaintiff of "imminent 
fear of peril;"; what EPSTEIN said and did, if anything, to create fear and apprehension 
in Plaintiff. In Count ill, Plaintiff is required to more definitely state the underlying factual 
allegations to support her claim as set forth in the statute, 18 M. 
§2422(b) and 
§2455. Rule 12(e). See discussion of law below herein. 
3. Also, Plaintiffs reference in Count III to 28 M. 
§2255, pertaining to habeas 
corpus proceedings is required to be stricken as immaterial. Rule 12(f). Plaintiff is 
required to more definitely state what statutory provision she is relying on. Rule 12 (e). 
WHEREFORE, Defendant respectfully requests that this Court dismiss Counts I and 
III, strike the immaterial statutory reference, and require Plaintiff to more definitely plead 
the underlying elements of her claims. 
Supporting Memorandum of Law 
Standard on Rule 12(b)(6) Motion To Dismiss 
As established by the Supreme Court in Bell Atlantic Corp. I. Twombly 127 
S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead 
"enough facts to state a claim to relief that is plausible on its face." Id, at 1974. 
Although the complaint need not provide detailed factual allegations, the basis for relief 
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'1,1 -KAM 
Document 52 
Entered 
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008 
Page 3 of 10 
Case No. CV-80381-Marra-Johnson 
Page No. 3 
in the complaint must state "more than labels and conclusions, and a formulaic 
recitation of the elements of a cause of action will not do." Id, at 1965. Further, "[f]actual 
allegations must be enough to raise a right to relief above the speculative level ... on the 
assumption that all the allegations in the complaint are true (even if doubtful in fact)." Id. 
On a motion to dismiss, the well pleaded allegations of plaintiffs complaint are taken as 
true and construed in the light most favorable to the plaintiff. 
. DeKalb County 
Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006). 
Significantly, the Supreme Court in Bell Atlantic Corp.'. Twombly abrogated the 
often cited observation that "a complaint should not be dismissed for failure to state a 
claim unless it appears beyond doubt that the plaintiff can prove not set of facts in 
support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley 
I. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme 
Court rejected the notion that "a wholly conclusory statement of claim [can] survive a 
motion to dismiss whenever the pleadings le[ave] open the possibility that a plaintiff 
might later establish some 'set of [undisclosed] facts' to support recovery." Id. As 
explained by the Supreme Court in Bell Atlantic Corp., supra at 1664-65: 
While a complaint attacked by a Rule 12(b)(6) moti 
to dismiss does not 
need detailed factual allegations ibid.: Saniva 
. American Bd. of 
Psychiatry and Neuroloay. Inc. 40 F.3d 247, 251 
.7 1994), a plaintiff's 
obligation to provide the "grounds" of his "entitle[ment] to relief" requires 
more than labels and conclusions, and a formuiic recitation of the elements 
of a cause of action will not do, see Papasan . Allain, 478 U.S. 265, 286, 
106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are 
not bound to accept as true a legal conclusion couched as a factual 
allegation"). Factual allegations 
st be enough to raise a right to relief 
above the speculative level, see 5 . W 
rii 
right & A. Miller Federal Practice and 
Procedure § 1216, pp. 235-236 
d ed.2004) (hereinafter Wright & Miller) 
("[T]he pleading must contain something more ... than ... a statement of facts 
that merely creates a suspicion [of] a legally cognizable right of action"), on 
the assumption that all the allegations in the complaint are true (even if 
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Page 4 of 10 
Case No. CV-80381-Marra-Johnson 
Page No. 4 
doubtful in fact), see, e.g. Swierkiewicl. SoremaN. A., 534 U.S. 506, 508, 
n. 1, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002 ; Neitzke I. Williams 490 U.S. 319, 
327, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1989) (" Rule 12(b)(6) does not 
I
countenance ... dismissals b sed on a judge's disbelief of a complaint's 
factual allegations"). Scheuer . Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 
40 L.Ed.2d 90 (1974) (a we -pleaded complaint may proceed even if it 
appears "that a recovery is very remote and unlikely"). 
Pursuant to Rule 12(e), a party may move for more definite statement of a 
pleading to which a responsive pleading is allowed where the pleading "is so vague or 
ambiguous that the party cannot reasonably frame a response." The motion is required 
to point out the defects and the desired details. Id. 
Count I - "Sexual Assault and Battery" is subiect to dismissal as Plaintiff has 
failed to state a claim upon which relief can be granted. 
It is well settled that this Court is to apply Florida substantive law in this action. 
Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term 
"assault and battery" is most commonly referred to as if it were a legal unit, or a single 
concept, "assault and battery are separate and distinct legal concepts, assault being the 
beginning of an act which, if consummated, constitutes battery." 3A FIa.Jur.2d Assault 
§1. An assault and battery are intentional acts. See generally, Spivey I. Battaglia 258 
So.2d 815 (Fla. 1972); and Travelers Indem. Co. I. PCR, Inc. 889 So.2d 779 (Fla. 
2004). 
An "assault" is an intentional, unlawful offer of corporal injury to another by force, 
or exertion of force directed toward another under such circumstances as to create a 
reasonable fear of imminent peril. See Lay'. Kremer, 411 So.2d 1347 (Fla. 1st DCA 
1982). It must be premised upon an affirmative act - a threat to use force, or the actual 
exertion of force. See 3A FIa.Jur.2d Assault §1("The essential element of the tort of 
assault is the violence offered, and not actual physical contact."). 
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Case No. CV-80381-Marra-Johnson 
Page No. 5 
As further explained in Florida Jurisprudence. 2d, Assault §1 —
An assault is defined as an intentional unlawful offer of corporal 
injury to another by force, or force unlawfully directed toward the person of 
another, under circumstances as to create a fear of Imminent peril, 
coupled with the apparent present ability to effectuate the attempt. At 
common law, a tortious assault is an act that puts another in reasonable 
apprehension of immediate bodily harm. 
In ¶12 of her Amended Complaint, Plaintiff does plead the requisite 
"touching" element of "battery," so that aspect of the assault and battery claim is not 
being challenged. With the standard of pleading established in Twombly, supra, in the 
context of assault, Plaintiff has failed to state a claim upon which relief can be granted. 
Rule 12(b)(6). As to the elements of assault, there are no factual allegations as to what 
was said or done to Plaintiff such that it constituted an "intentional, unlawful offer of 
corporal injury to another by force, or exertion of force directed toward another under 
such circumstances as to create a reasonable fear of imminent peril." See ¶12-13 of 
Am. Comp. In ¶13 alleges that JANE DOE NO. 5 (and another unidentified girl) "were 
then able to get dressed, leave the room and go back downstairs. Esptein gave both 
girls money for this 'massage.'" Allegations as to circumstances creating a fear of 
imminent peril are lacking. 
Under applicable law, Plaintiff is required to give more than labels and 
conclusions, and a formulaic recitation of the elements of a cause of action. Twomblv 
supra. Plaintiff is required to allege the facts of what was done to her; what EPSTEIN 
said and did, if anything, to create fear and apprehension in Plaintiff. 
As noted in the introduction and as this Court is well aware, there is more than 
one action brought against this Defendant attempting to allege similar sounding claims. 
With all due respect, the details as to a particular claim asserted by a particular Plaintiff 
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Case No. CV-80381-Marra-Johnson 
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are important to give this Defendant fair notice of Plaintiff's claim so he may properly 
respond. Accordingly, under applicable law, Plaintiff has failed to state a claim for 
"sexual assault and battery" has Plaintiff has failed to plead requisite factual allegations 
concerning the assault. 
In the alternative to dismissing Count I, Defendant requests that Plaintiff be 
required to give more definite statement as to what was done to her; what EPSTEIN 
said and did, if anything, to create fear and apprehension in Plaintiff; in pleading the 
elements of assault. Rule 12(e). 
Ill - "Coercion and Enticement to Sexual Activity in Violation of 18 
42422" - is subject to dismissal as Plaintiff has failed to state a claim 
upon which relief can be ar 
Rule 12031(6). Count ill also contains an 
immaterial reference to 28 
. 42256, which is required to be stricken 
and more definitely stated. 
Count Ill of Plaintiff's Complaint attempts to assert a claim for "Coercion and 
Enticement to Sexual Activity in Violation of 18 
. §2422." In her prayer for relief in 
Count Ill, Plaintiff "demands judgment against Defendant Jeffrey Epstein for all 
damages available under 28 
. §2255(a), 
." 
Although the reference to "28 
§2255," pertaining to habeas corpus 
proceedings — federal custody and remedies on motion attacking sentence, is probably 
a typographical error by Plaintiff, and the reference to "28" was meant to be "18," 
Defendant requests that Plaintiff correct this error so that Defendant may have fair 
notice of the claim Plaintiff is attempting to assert. 
Whether or not the "28" is 
typographical error, Defendant is still entitled to dismissal of the count. 
The applicable version of these statutory provisions, (pre-2006 Amendments, as 
the Amended Complaint alleges a time period of "in or about 2002-2003," ¶8), provides: 
EFTA00175854