EFTA00175214

Case 9:08-cv-80993-KAM 
Document 86 
Entered on FLSD Docket 06/10/2009 
Page 7 of 10 
Jane Doe No. 7 v. Epstein 
Page 7 
7. Plaintiff's claims are barred by the applicable statute of limitations. 
8. As to Plaintiff's claims for punitive damages in Count I — "Sexual Assault & 
Battery," and Count II — "Intentional Infliction of Emotional Distress," such claims are 
subject to the limitations as set forth in §768.72, et seq., Florida Statutes. 
9. As to Plaintiff's claims for punitive damages in Count I — "Sexual Assault & 
Battery," and Count II — "Intentional Infliction of Emotional Distress," such claims are 
subject to the constitutional limitations and guideposts as set forth in BMW of North 
America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057 
(2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Liqoet Group, Inc., 945 
So.2d 1246 (Fla. 2006). The Due Process Clause of the Fourteenth Amendment of the 
United States Constitution and Florida's Constitution, Art. I, §§2 and 9, prohibit the 
imposition of grossly excessive or arbitrary punishments 
10.As to Plaintiff's claims for punitive damages in Count I — "Sexual Assault & 
Battery," and Count II — "Intentional Infliction of Emotional Distress," the determination of 
whether or not Defendant is liable for punitive damages Is required to be bifurcated from 
a determination of the amount to be imposed. 
11. Plaintiff has failed to state a cause of action for sexual assault and/or battery 
under Count I. 
12. As to Count III, Plaintiff has failed to plead a cause of action as she does not and 
can not show a violation of a predicate act under 18 U.S.C. §2255 (2005). 
EFTA00175234

Case 9:08-cv-80993-KAM 
Document 86 
Entered on FLSD Docket 06/10/2009 
Page 9 of 10 
Jane Doe No. 7 v. Epstein 
Page 9 
applying a novel construction of a criminal statute to conduct that neither the statute nor 
any prior judicial decision has fairly disclosed to be within its scope. 
16.The applicable version of 18 U.S.C. §2255 creates a cause of action on behalf of 
a "minor." Plaintiff had attained the age of majority at the time of filing this action, and 
accordingly, her cause of action is barred. 
17.Because Plaintiff has no claim under 18 U.S.C. §2255, this Court is without 
subject matter jurisdiction as to all claims asserted. 
18.Application of the 18 U.S.C. §2255, as amended, effective July 27, 2006, is in 
violation of the constitutional principles of due process, the "Ex Post Facto" clause, and 
the Rule of Lenity, in that in amending the term "minor" to "person" as to those who may 
bring a cause of action impermissibly and unconstitutionally broadened the scope of 
persons able to bring a §2255 claim. 
19. 18 U.S.C. §2255 violates the Equal Protection Clause of the 141h Amendment 
under the U.S. Constitution, and thus Plaintiff's claim thereunder is barred. 
20. 18 U.S.C. §2255 violates the constitutional guarantees of procedural and 
substantive due process. Procedural due process guarantees that a person will not be 
deprived of life, liberty or property without notice and opportunity to be heard. 
Substantive due process protects fundamental rights. Accordingly, Plaintiffs cause of 
action thereunder is barred. 
WHEREFORE Defendant requests that this Court deny the 
lief sought by Plaintiff. 
Robert D. I ritton, Jr. 
Attorney f r Defendant Epstein 
EFTA00175235

Case 9:08-cv-80893-KAM 
Document 38 
Entered on FLSD Docket 04/17/2009 
Page 1 of 18 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No.: 08-CIV-80893 - MARRA/JOHNSON 
JANE DOE, 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
/ 
PLAINTIFF'S FIRST AMENDED COMPLAINT 
Parties, Jurisdiction and Venue 
Plaintiff, Jane Doe, hereby brings this First Amended Complaint against 
Defendant, Jeffrey Epstein, and states as follows: 
1. 
This is an action for damages in an amount in excess of $50,000,000.00, 
exclusive of interest and costs. 
2. 
This First Amended Complaint is brought under a fictitious name in order 
to protect the identity of Plaintiff, Jane Doe, because this Complaint makes allegations 
of sexual assault and child abuse of a then minor. 
3. 
At all times material to this cause of action, Plaintiff, Jane Doe, was a 
resident of Palm Beach County, Florida. 
4. 
At all times material to this cause of action, Defendant, Jeffrey Epstein, 
was a resident of the State of New York. 
5. 
At all times material to this cause of action, Defendant, Jeffrey Epstein, 
had a residence located in Palm Beach County, Florida. 
EFTA00175236

Case 9:08-cv-80893-KAM 
Document 38 
Entered on FLSD Docket 04/17/2009 
Page 3 of 18 
12. 
Plaintiff Jane Doe was contacted by Defendant Jeffrey Epstein himself or 
or other unknown employees or assistants of Defendant Epstein on 
numerous occasions, and she was often times brought to Defendant Epstein's 
residence with the assistance of Defendant Epstein's assistants. 
13. 
or other employees/assistants of Defendant Epstein would 
often arrange with the Yellow Cab cab company to take minor girls, including Jane Doe, 
to Defendant Epstein's house. 
14. 
Once the then minor girl, including Plaintiff Jane Doe, arrived at Epstein's 
house, the assistants and employees left the then minor Plaintiff and other minor girls 
alone in a room at the defendant's mansion. Subsequently, Defendant, Jeffrey Epstein, 
himself would appear, remove his clothing, and direct the then minor Plaintiff to remove 
her clothing. He would then perform one or more lewd, lascivious, and sexual acts, 
including, but not limited to, 
of the then minor Plaintiffs sexual 
organs, using 
on the then minor Plaintiff, and 
the then minor Plaintiff. 
15. 
Defendant Epstein traveled to his mansion in Palm Beach for the purpose 
of luring minor girls to his mansion to sexually abuse or batter them; he used the 
telephone to contact these minor girls for the purpose of coercing them into acts of 
prostitution and to enable himself to commit sexual battery against them and acts of 
lewdness in their presence, and he conspired with others, including his assistants 
and 
to further commit these acts and to avoid police 
detection. 
3 
EFTA00175237

Case 9:08-cv-80893-KAM 
Document 38 
Entered on FLSD Docket 04/17/2009 
Page 5 of 18 
Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should 
have known of the plaintiff, Jane Doe's minority. 
21. 
The above-described acts were perpetrated upon the person of the then 
minor Plaintiff regularly and on dozens of occasions. 
22. 
In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, 
Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state 
crimes involving the solicitation of minors for prostitution and the procurement of minors 
for the purposes of prostitution, for which Defendant Epstein was sentenced to 18 
months incarceration in Palm Beach County jail to be followed by 12 months community 
control (house arrest). 
COUNT I 
Sexual Battery upon a Minor 
23. 
The Plaintiff, Jane Doe, repeats and realleges paragraphs 1 through 21 
above. 
24. 
On numerous occasions, Defendant Epstein did in fact intentionally touch 
Plaintiff, Jane Doe, on her person against her will and/or without her legal consent. 
25. 
Defendant Epstein battered her sexually, in that he touched her in intimate 
areas of her body and person in an offensive manner while she was a minor child, and 
therefore the touchings were without legal consent. 
26. 
Defendant Epstein touched her in intimate areas of her body on dozens of 
occasions between approximately February 2003 and approximately June 2005. 
27. 
The conduct described in this count constitutes battery against the person 
of the then minor Plaintiff. 
5 
EFTA00175238

Case 9:08-cv-80893-KAM 
Document 38 
Entered on FLSD Docket 04/17/2009 
Page 7 of 18 
federal offenses, the Defendant, Jeffrey Epstein, entered into a Non-Prosecution 
Agreement with the Federal Government, wherein he acknowledged Plaintiff Jane Doe 
as a victim of certain criminal offenses he committed against Jane Doe. 
32. 
The Plaintiff, Jane Doe, was in fact a victim of one or more offenses 
enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause 
of action against the Defendant, Jeffrey Epstein, pursuant to this Section of the United 
States Code and the agreement between the Defendant, Jeffrey Epstein, and the 
United States Government. 
33. 
Specifically, Defendant Epstein: 
(a) 
knowingly conspired with others known and unknown to use a 
facility or means of interstate commerce to knowingly persuade, induce, or entice 
minor females, including Plaintiff Jane Doe, to engage in prostitution, in violation 
of title 18, United States Code, Section 2422(b). 
(b) 
knowingly and willfully conspired with others known (such as 
M
)
 
and unknown to travel in interstate commerce for the purpose of 
engaging in illicit sexual conduct with minors, including Plaintiff Jane Doe, as 
defined in 18 U.S.C. § 2423(f), with minor females, in violation fo Title 18, United 
States Code, Section 2423(b); all in violation of Title 18, United States Code, 
Section 2423(e); 
(c) 
used a facility or means of interstate or foreign commerce to 
knowingly persuade, induce, or entice minor females, including Plaintiff Jane 
Doe, to engage in prostitution; in violation of Title 18, United States Code, 
Section 2422(b); 
7 
EFTA00175239

Case 9:08-cv-80893-KAM 
Document 38 
Entered on FLSD Docket 04/17/2009 
Page 9 of 18 
COUNT III 
Intentional Infliction of Emotional Distress 
35. 
Plaintiff, Jane Doe, adopts and realleges paragraphs 1 through 22 above. 
36. 
Defendant Jeffrey Epstein's inappropriate sexual conduct towards the then 
minor Plaintiff was extreme and outrageous; under the circumstances, his conduct was 
outrageous and so extreme in degree that it should not be tolerated in a civilized 
community. 
37. 
Defendant Jeffrey Epstein acted with the intent to cause severe emotional 
distress or with reckless disregard of the high probability of causing severe emotional 
distress upon the then minor Plaintiff. 
38. 
Defendant Jeffrey Epstein was well aware that Plaintiff was a minor child, 
and yet he continued to sexually abuse her, intentionally and recklessly causing Plaintiff 
to suffer extreme emotional distress. 
39. 
Defendant Jeffrey Epstein's intentional, deliberate and reckless conduct 
caused severe emotional distress to the Plaintiff, Jane Doe. Defendant, at the time he 
committed these numerous sexual assaults on Plaintiff, Jane Doe, had a specific intent 
to harm the then minor Plaintiff, and his conduct did so harm the Plaintiff. 
40. 
As a direct and proximate result of Defendant, Jeffrey Epstein's intentional 
and reckless conduct, Plaintiff, Jane Doe, has in the past suffered and in the future will 
continue to suffer severe emotional distress, physical injury, pain and suffering, 
psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, 
loss of dignity, invasion of her privacy and other damages associated with Defendant, 
Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and 
9 
EFTA00175240

Case 9:08-cv-80893-KAM 
Document 38 
Entered on FLSD Docket 04/17/2009 
Page 11 of 18 
violation of Florida Statutes §772.103(3)-(4), as further outlined in detail in the RICO 
statement filed with this court. 
44. 
This enterprise was separate and distinct from Epstein himself and had a 
definite hierarchical structure. Epstein served informally but effectively as the leader, 
C.E.O, or "boss" of this organization, directing his underlings how to recruit and procure 
young girls for his sexual activities and when to bring the girls to his mansion. Epstein's 
key "lieutenant" in the organization was MI 
who served as both his scheduler and a 
recruiter/procurer of the girls. Marcinkova also served as a recruiter and helped Epstein 
satisfy his criminal sexual desires by, on occasion, directly participating in sexual abuse 
and prostitution of the minor girls. Epstein also used otherwise-legitimate business 
activities to help further the purpose of the criminal enterprise. These apparently 
legitimate activities provided "cover" for Epstein and his associates to commit the 
crimes. 
Epstein and his associates maintained the appearance of running an 
upstanding investment business, as well as other legitimate businesses with 
connections to modeling agencies and other powerful business and political people, to 
discourage the minor girls from reporting the abuse to law enforcement. 
45. 
Defendant Jeffrey Epstein participated in this enterprise through a pattern 
of criminal activity in that he engaged in at least two incidents of criminal activity, as 
defined in Florida Statute 772.102 and as described below, that have the same or 
similar intents, results, accomplices, victims, or methods of commission and are not 
isolated incidents. 
46. 
Defendant Jeffrey Epstein engaged in criminal activity by committing, 
attempting to commit, conspiring to commit or soliciting, coercing or intimidating another 
11 
EFTA00175241

Case 9:08-cv-80893-KAM 
Document 38 
Entered on FLSD Docket 04/17/2009 
Page 13 of 18 
47. 
The criminal acts of Defendant Epstein occurred repeatedly over a 
substantial period of time and were not isolated events. 
48. 
Under Defendant, Jeffrey Epstein's plan, scheme, and enterprise, 
Defendant, Jeffrey Epstein, paid employees and underlings, including but not limited to 
to bring him minor girls to his Palm Beach mansion in order for the 
Defendant to solicit, induce, coerce, entice, compel or force such girls to engage in acts 
of prostitution and sexual misconduct with Defendant Epstein and sometimes 
, and to otherwise commit acts of sexual battery thereon. 
49. 
Plaintiff, Jane Doe, was the victim of Defendant, Jeffrey Epstein's plan, 
scheme, and enterprise and was so injured by reason of his violations of the provisions 
of s. 772.104. Plaintiff, Jane Doe, was called on the telephone by Defendant Epstein 
and other employees of his, including 
and transported to the Defendant, 
Jeffrey Epstein's residence, where she was placed in a room along with the Defendant, 
enticed to commit acts of prostitution, and had acts of sexual battery and sexual 
exploitation committed against her. Defendant, Jeffrey Epstein, conspired with his 
assistants and employees in order to accomplish their common motive or intent of 
seeking out, gaining access to, and exploiting minor children such as the Plaintiff, Jane 
Doe, in the aforementioned ways, and he further conspired with his employees, 
assistants and underlings to ensure that the crimes of this criminal enterprise were 
concealed or undetected by law enforcement. 
50. 
After law enforcement began to detect the criminal activities of Defendant 
Epstein and the other persons involved in the criminal enterprise, the enterprise used 
resources and information to conceal the illegal activities of the enterprise, threaten the 
13 
EFTA00175242

Case 9:08-cv-80893-KAM 
Document 38 
Entered on FLSD Docket 04/17/2009 
Page 15 of 18 
COUNT V 
Cause of Action Pursuant to Florida Statute 796.09 
Against Defendant, Jeffrey Epstein 
54. 
Plaintiff adopts and realleges paragraphs 1 through 22 above. 
55. 
The allegations contained herein in Count II are a separate and distinct 
legal remedy. 
56. 
Defendant, Jeffrey Epstein, was a wealthy and powerful man, and Plaintiff 
was an economically disadvantaged and impressionable minor. 
57. 
Defendant, Jeffrey Epstein, used his vast wealth and power to coerce 
Plaintiff into prostitution and/or coerced her to remain in prostitution. 
58. 
Defendant, Jeffrey Epstein, coerced Plaintiff into prostitution in one or 
more of the following ways: 
A. 
Domination of her mind and body through exploitive techniques; 
B. 
Inducement; 
C. 
Promise of greater financial rewards; 
D. 
Exploitation of a condition of developmental disability, cognitive 
limitation, affective disorder, and/or substance dependency; 
E. 
Exploitation of human needs for food, shelter or affection; 
F. 
Exploitation of underprivileged and vulnerable economic condition 
or situation; 
G. 
Use of a system of recruiting other similarly situated minor girls to 
further coerce and induce Plaintiff into the lifestyle of prostitution; and 
15 
EFTA00175243

Case 9:08-cv-80893-KAM 
Document 38 
Entered on FLSD Docket 04/17/2009 
Page 17 of 18 
Respectfully Submitted, 
Plaintiff, by One of Her Counsel, 
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 
Telephone 
Facsimile 
Florida Bar 'o.: 
E-mail: 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on April 17, 2009, I electronically filed the foregoing 
document with the Clerk of Court using CM/ECF. I also certify that the foregoing is 
being served this day upon all counsel of record identified 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 counsel or parties who are 
not authorized to receive electronically Notices of Electronic Filing. 
s/ Bradley J. Edwards 
Bradley J. Edwards 
17 
EFTA00175244

Case 9:08-cv-80993-KAM 
Document 52 
Entered on FLSD Docket 05/07/2009 
Page 1 of 12 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80993-MARRA 
JANE DOE NO. 7, 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
MOTION TO COMPEL AND/OR IDENTIFY JANE DOE #7 IN THE STYLE OF 
THIS CASE AND MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY 
SUBPOENAS FOR PURPOSES OF DISCOVERY, OR ALTERNATIVELY, 
MOTION TO DISMISS SUA SPONTE, WITH INCORPORATED 
MEMORANDUM OF LAWI 
Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and 
through his undersigned attorneys, hereby requests that this Court enter an order 
identifying in the style of this case the complete legal name of the Plaintiff, JANE 
DOE #7 ("JANE DOE"), to substitute her complete legal name in this case in 
place of "JANE DOE" and, equally Important, allowing Defendant to identify her in 
various subpoenas that Epstein must serve so Epstein can defend this case or, 
alternatively, Motion to Dismiss Entire Action Sua Sponte. In support, Mr. 
Epstein states as follows: 
1 Several of the discovery responses attached to this Motion and to the 
companion "Motions to Identify" filed in other related matters are 
markedly different. 
Therefore, each requires the court's attention on 
an individual basis. 
1 
EFTA00175245

Case 9:08-cv-80993-KAM 
Document 52 
Entered on FLSD Docket 05/07/2009 
Page 3 of 12 
Coercion and Enticement to Sexual Activity in violation of 18 U.S.C. §2422, 
plaintiff claims entitlement to recover for ". . .personal injury, including mental, 
psychological and emotional damages" 
¶33, Am. Comp., DE 19. See also 
Exhibit "A", Interrogatory Response Number 9. Plaintiff also claims entitlement 
to "punitive damages" and "actual and compensatory damages." DE 19. 
6. 
Epstein has a constitutional due process right to defend himself and 
to seek the production of information that will assist in his defense of the 
allegations in the Amended Complaint. In this case, Plaintiffs counsel objected 
to Epstein serving subpoenas on Plaintiff's treating physicians and other third 
parties. Thus, this motion seeks to identify JANE DOE in the style of this case, to 
identify JANE DOE in various third-party subpoenas for discovery purposes and, 
alternatively, to dismiss this entire action sua sponte. 
The undersigned's 
experience in "Jane Doe" lawsuits is that once a Plaintiff is identified, other 
individuals come forward in the discovery phase with information which often 
directly contradicts allegations as to the events and damages. For instance, 
witnesses may testify that Plaintiff was paid by others for similar sexual acts she 
claims Mr. Epstein forced upon her or that she willingly participated in certain 
act(s) that would negate or lessen her damages. This goes directly to Plaintiff's 
damage claim. 
7. 
Likewise, subpoenas must be issued to third-party treaters and 
current and former employers, and those subpoenas will seek to obtain records 
related directly to Plaintiff's claims and her damages (i.e., her claim for severe 
and permanent traumatic injuries, including mental, psychological and emotional 
3 
EFTA00175246

Cse 9:08-cv-80993-KAM 
Document 52 
Entered on FLSD Docket 05/07/2009 
Page 5 of 12 
is not the case when a Plaintiff places her mental, emotional, psychological and 
physical condition at issue. 
9. 
Moreover, when an order from the court is attached to the 
Subpoena, treaters and other third parties produce the records and show up to 
the depositions with the records requested because the deponent knows what to 
bring by virtue of knowing the identity of the Plaintiff. 
10. 
Epstein's counsel intends to serve and depose witnesses duces 
tecum. If Epstein is not permitted to identify JANE DOE, how will any deponent 
know who the parties are and what to bring to the deposition pursuant to the 
duces tecum? Further, how will Epstein be able to defend the claims. Just like 
the Plaintiff, Epstein is entitled to due process. 
11. 
While it is within the sound discretion of this court to allow a party to 
proceed anonymously, Plaintiff should not attempt to utilize that discretion as a 
shield from legitimate and necessary discovery. Epstein has a fundamental due 
process right to conduct discovery. 
b. 
Motion To Identify JANE DOE In Style Of This Case 
12. 
As discussed below, Epstein has fundamental due process right to 
defend himself in this civil litigation. 
While JANE DOE travels under a 
pseudonym, various newspaper articles identifying Epstein have been released 
discussing the alleged claims against him. Allowing JANE DOE to litigate this 
matter under a pseudonym is preventing Epstein from defending this suit 
including, but not limited to, preventing him from locating individuals that may 
have information about this lawsuit and information about JANE DOE that may 
5 
EFTA00175247

Ca 
9:08-cv-80993-KAM 
Document 52 
Entered on FLSD Docket 05/07/2009 
Page 7 of 12 
Doe v. Frank, 951 F.2d at 323. 
Plaintiff does not fall under any of the factors. Moreover, even if she did 
meet one of the factors, "[t]he fact that [a] Doe [Plaintiff] may suffer some 
personal embarrassment, standing alone, does not require the granting of a 
request to proceed under a pseudonym." Id; see also Doe v, Rostker, 89 F.R.D. 
159 (N.D. Calif. 1981). Any substantial privacy interests JANE DOE has must 
outweigh the customary and constitutionally embedded presumption of openness 
to judicial proceedings. Doe v. Frank, 951 F.2d at 323; Poe v. Bergstron, 2009 
WL 528623 (C.A.9(Or.))(denying request to proceed anonymously in civil action 
by Plaintiff where Plaintiffs arrest, prosecution and acquittal were matters of 
public record). 
14. 
In Sweetland v. State, 535 So.2d 646 (Fla. 18t DCA 1988), the court 
reasoned that the purpose of discovery is to eliminate the likelihood of surprise 
and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 
1.280(b)(1); see also Surf Drugs. Inc., v. Vermette, 236 So.2d 108, 111 (Fla. 
1970)(stating that the rules of discovery should be afforded broad and liberal 
treatment to effectuate their purpose), citing., Hickman v. Taylor 329 U.S. 495, 
501, 507 (1947). 
15. 
Next, the right to go to court to resolve disputes is a fundamental right. 
D.R. Lakes, Inc. v. Brandsmart U.S.A. of West Palm Beach, 819 So.2d 971 (Fla. 4th
DCA 2002). All litigants are afforded an equal opportunity. Lingle v. Dion, 776 
So.2d 1073 (Fla. 4th DCA 2001). The Florida Constitution establishes the right 
commonly known as access to courts. Mitchell v. Moore, 786 So.2d 521 (Fla. 
7 
EFTA00175248

6se 9:08-cv-80993-KAM 
Document 52 
Entered on FLSD Docket 05/07/2009 
Page 9 of 12 
others, diminished sense of future prospects, corruption of morals, distorted and 
disrupted development, loss of normal adolescent ideals." (Emphasis Added). 
W. Epstein is also entitled to know, among other things, whether she had any 
physical complaints or whether there was ever any evidence of physical battery 
on JANE DOE's body from the acts she complains of in the Amended Complaint. 
The need to serve third-party subpoenas on medical doctors is a basic discovery 
need related to the claims alleged by JANE DOE for which Plaintiff's counsel 
refuses to compromise. Balas v. Ruzzo 703 So.2d 1076 (Fla. 5th DCA 1997), 
rev. denied, 719 So.2d 286 (Fla. 1998)(discoverability of Plaintiff's history of 
sexual activity is relevant to damages); United States v. Bear Stops 997 F.2d 
451 (81h Cir. 1993)(deals with "admissibility of other acts of sexual abuse by 
individuals other than the defendant to explain why a victim of abuse exhibited 
behavioral manifestations of a sexually abused child.") 
If Plaintiff saw a 
psychologist or other physician during or after the time periods she claims she 
was assaulted by Epstein but either did not discuss or did discuss the incidents 
(or lack thereof) would be directly relevant to her damage claims. Plaintiff seeks 
physical and emotional/mental personal injury type damages, and the Epstein 
must conduct his own discovery thereon. 
See supra. 
No valid discovery 
objections or exemptions exist preventing necessary and reasonable discovery. 
To hold otherwise prevents Mr. Epstein from preparing and defending this matter. 
19. 
In defending this lawsuit, Mr. Epstein should be permitted broad 
discovery, whether admissible at trial or not. Fed.R.Civ.Pro. 26 provides, in 
pertinent part, that "parties may obtain discovery regarding any matter, not 
9 
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Case 9:08-cv-80993-KAM 
Document 52 
Entered on FLSD Docket 05/07/2009 
Page 11 of 12 
would ultimately result in reversible error at any trial. 
II. Conclusion 
22. 
Epstein requests the following relief: 
a. 
That JANE DOE be identified by her legal name in the style of 
this case; 
b. 
That Epstein be granted leave to identify JANE DOE by her 
legal name In Third-Party Subpoenas (but not file them in Court 
or, if required, in a redacted form); and 
c. 
That, on an alternative basis, this court dismiss this action Sua 
Sponte until such time as JANE DOE Identifies herself in the 
style of this matter. Doe v. Rostker, 89 F.R.D.at 163. 
WHEREFORE, Epstein, Jeffrey Epstein, respectfully requests that this 
Court enter said order granting the relief requested above, and for such other 
and further relief as this Court may deem jus 
By: 
ROBERT CRI TON, JR., ESQ. 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was electronically 
filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing 
document is being served this day on all counsel of record identified on the 
following Service List in the manner specified by CM/ECF on this 
day of gal 
, 2009: 
Stuart S. Mermelstein, Esq. 
Adam D. Horowitz, Esq. 
Mermelstein & Horowitz, P.A. 
18205 Biscayne Boulevard 
Suite 2218 
60 
Fax: 
ssmasexa useattornev.com 
EFTA00175250

CM/ECF, Live Database - flsd 
Page 1 of 14 
LRJ, MEDREQ, REF_DISCOV 
U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE #: 9:08-cv-80993-KAM 
Jane Doe No. 7 v. Epstein 
Assigned to: Judge Kenneth A. Marra 
Referred to: Magistrate Judge Linnea R. Johnson 
Lead case: 9:08-cv-80119-KAM 
Member case: (View Member Case) 
Case: 9:09-cv-80802-KAM 
Cause: 28:1391 Personal Injury 
Plaintiff 
Jane Doe No. 7 
Date Filed: 09/10/2008 
Jury Demand: Plaintiff 
Nature of Suit: 710 Labor: Fair 
Standards 
Jurisdiction: Federal Question 
represented by Adam 1). 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: 931-0877 
Email: jherman@hermanlaw.com 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Stuart S. Mermelstein 
Mermelstein & Horowitz PA 
18205 Biscayne Boulevard 
Suite 2218 
https://eculsd.useourts.govicgi-bin/D1ctRpt.pl?667278296697325-L_801_0-1 
6/10/2009 
EFTA00175251

ONECF Live Database - flsd 
Page 2 of 14 
Miami FL 33160 
V. 
Defendant 
Jeffrey Epstein 
Fax: 931-0877 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
represented by Robert Deweese Critton , Jr. 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Amiens 
United States of America 
represented by 
Fax: 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Michael James Pike 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Fax: 51 -3148 
Email: 
ATTORNEY TO BE NOTICED 
United States Attorney's Office 
500 East Broward Blvd 
7th Floor 
derdale , FL 33394 
, ext. 3546 
Fax: 356-7336 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
https://ectflsd.uscourts.gov/cgi-bin/DktRpt.pr667278296697325-L_801_0-1 
6/10/2009 
EFTA00175252

CWECF, Live Database - flsd 
Page 3 of 14 
Date Filed 
# that Docket Text 
09/10/2008 
1 
F. 
463.9 
KB 
COMPLAINT against Jeffrey Epstein Filing fee $ 350.00. Receipt#: 
544158, filed by Jane Doe No. 7.(vt) (Entered: 09/10/2008) 
09/10/2008 
2 
r 
99.1 
KB 
Summons Issued as to Jeffrey Epstein. (vt) (Entered: 09/10/2008) 
09/15/2008 
3 
r 
130.8 
KB 
NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf 
of Jeffrey Epstein (Critton, Robert) (Entered: 09/15/2008) 
10/03/2008 
4 
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ACKNOWLEDGMENT OF SERVICE Executed as to 2 Summons Issued, 
1 Complaint Acknowledgement filed by Jane Doe No. 7. (Herman, Jeffrey) 
(Entered: 10/03/2008) 
10/03/2008 
5 
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26.1 
Ica 
NOTICE of Striking 4 Acknowledgment of Service filed by Jane Doe No. 7 
by Jane Doe No. 7 (Herman, Jeffrey) (Entered: 10/03/2008) 
10/03/2008 
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SUMMONS (Affidavit) Returned Executed by Jane Doe No. 7. Jeffrey 
Epstein served on 9/23/2008, answer due 10/14/2008. (Herman, Jeffrey) 
(Entered: 10/03/2008) 
10/14/2008 
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1.1 
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Defendant's MOTION to Dismiss 1 Complaint, MOTION for More 
Definite Statement by Jeffrey Epstein. Responses due by 10/31/2008 
(Critton, Robert) (Entered: 10/14/2008) 
10/20/2008 
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46.3 
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ORDER OF TRANSFER. Case is transferred to Judge Kenneth A. Marra 
for all further proceedings. Judge Daniel T. K. Hurley no longer assigned to 
case. Signed by Judge Daniel T. K. Hurley on 10/17/2008 and Judge 
Kenneth A. Marra on 10/17/2008. (jdo) (Entered: 10/20/2008) 
10/21/2008 
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CERTIFICATION AND ORDER OF TRANSFER TO MAGISTRATE 
JUDGE. Case Transferred to Magistrate Judge Linnea R. Johnson as 
referral judge in case. Magistrate Judge James M. Hopkins no longer 
assigned as referral judge(s) in case. Signed by Magistrate Judge James M. 
Hopkins on 10/21/08. (Iwl) (Entered: 10/21/2008) 
10/21/2008 
Magistrate Judge Linnea R. Johnson added per Order at DE 9 . (bb) 
(Entered: 10/28/2008) 
10/22/2008 io r
63.6 
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Order Requiring Counsel to Confer and File Joint Scheduling Report. 
Signed by Judge Kenneth A. Marra on 10/21/2008. (ir) (Entered: 
10/22/2008) 
10/31/2008 II
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MEMORANDUM in Opposition re 7 Defendant's MOTION to Dismiss 1 
Complaint MOTION for More Definite Statement filed by Jane Doe No. 7. 
(Attachments: # 1 Exhibit A)(Herman, Jeffrey) (Entered: 10/31/2008) 
11/10/2008 
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RESPONSE/REPLY to 11 Memorandum in Opposition to Defendant's 
https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?667278296697325-L_801_0-1 
6/10/2009 
EFTA00175253