EFTA00175214

CMJECV- Live Database - flsd 
Page 4 of 14 
290.8 
1CB 
Motion to Dismiss filed by Jeffrey Epstein. (Critton, Robert) (Entered: 
11/10/2008) 
12/17/2008 
13. r 
2.1
JAB 
NOTICE of Filing Discovery: Joint Scheduling and Discovery Report by 
Jeffrey Epstein.(Pike, Michael) (Entered: 12/17/2008) 
12/17/2008 
15 
JOINT SCHEDULING REPORT - Rule 16.1. See image DE 13 (1k) 
(Entered: 12/18/2008) 
12/18/2008 
14 
r 
82.5 
" 
SCHEDULING ORDER: Jury Trial set for 2/8/2010 09:00 AM in West 
Palm Beach Division before Judge Kenneth A. Marra., Calendar Call set 
for 2/5/2010 10:00 AM in West Palm Beach Division before Judge 
Kenneth A. Main., Amended Pleadings due by 2/2/2009., Discovery due 
by 10/5/2009., Dispositive Motions due by 10/23/2009. 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 12/17/2008. (ir) 
(Entered: 12/18/2008) 
12/18/2008 
16 
Clerks Notice of Docket Correction and Instruction to Filer re 13 Notice of 
Filing Discovery filed by Jeffrey Epstein. ERROR - Wrong Event 
Selected; Correction - Redocketed by Clerk as Scheduling Report-Rule 26 
(f) B . Instruction to Filer - In the future, please select the proper event. It 
is not necessary to refile this document. (1k) (Entered: 12/18/2008) 
02/12/2009 17 r
tom 
KB 
OPINION AND ORDER granting in part and denying in part 1 Motion to 
Dismiss; denying 7 Motion for More Definite Statement. Signed by Judge 
Kenneth A. Marra on 2/12/2009. (ir) (Entered: 02/12/2009) 
02/23/2009 
18 r 
21.1
KB 
NOTICE by Jane Doe No. 7 of Change of Name of Plaintiffs Counsel 
(Horowitz, Adam) (Entered: 02/23/2009) 
02/27/2009 
19 r 
35.8
KB 
AMENDED COMPLAINT, filed by Jane Doe No. 7.(Horowitz, Adam) 
(Entered: 02/27/2009) 
03/04/2009 
20 
r
376.1 
KB
Defendant's MOTION for Extension of Time to File Response as to 12 
Amended Complaint with proposed Order by Jeffrey Epstein. (Critton, 
Robert) (Entered: 03/04/2009) 
03/05/2009 
21 
ENDORSED ORDER granting 20 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) 
03/25/2009, 22 
r
2.2 
MB
Defendant's MOTION to Stay re 19 Amended Complaint by Jeffrey 
Epstein. Responses due by 4/13/2009 (Attachments: # 1 Exhibit A, # 2 
Exhibit B)(Pike, Michael) (Entered: 03/25/2009) 
03/27/2009 
23 
MOTION for Protective Order and to Quash Subpoena for Deposition of 
Jane Doe No. 4, Motion to Consolidate Cases for Purposes of Discovery, 
https://eculsd.uscourts.govicgi-bitilDktRpt.p17667278296697325-L_801_0-11 
6/10/2009 
EFTA00175254

CIWECF r Live Database - flsd 
Page 5 of 14 
r 
435.3 
KB
and Incorporated Memorandum of Law in Support by Jane Doe No. 7. 
(Attachments: # 1 Exhibit A, # 2 Exhibit B)(Mermelstein, Stuart) (Entered: 
03/27/2009) 
03/27/2009 
24 
MOTION to Consolidate Cases for purposes of discovery ( Responses due 
by 4/13/2009), MOTION to Quash by Jane Doe No. 7. See image DE 23 
(1k) (Entered: 03/30/2009) 
03/30/2009 
25 
Clerks Notice of Docket Correction and Instruction to Filer re 23 MOTION 
for Protective Order and Incorporated Memorandum of Law in Support 
filed by Jane Doe No. 7. ERROR - Motion with Multiple Reliefs flied as 
One Relief; Correction - Additional relief(s) 24 MOTION TO QUASH 
AND MOTION CONSOLIDATE CASES docketed by Clerk. Instruction 
to filer - In the future, please select all applicable reliefs. It is not necessary 
to refile this document. (1k) (Entered: 03/30/2009) 
04/02/2009 
26 r
2.4 
"s 
Defendant's MOTION to Compel Response to 1st RTP by Jeffrey Epstein. 
Responses due by 4/20/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 
3 Exhibit C, # 4 Exhibit D)(Critton, Robert) (Entered: 04/02/2009) 
04/02/2009 
27 
r
2.0 
MB
Defendant's MOTION to Compel Answers to 1st Interrogs by Jeffrey 
Epstein. Responses due by 4/20/2009 (Attachments: # 1 Exhibit A, # 2 
Exhibit B, # 3 Exhibit CXCritton, Robert) (Entered: 04/02/2009) 
04/02/2009 
28 r 
36" 
ics 
Defendant's ANSWER and Affirmative Defenses to Amended Complaint 
(Second) by Jeffrey Epstein.(Critton, Robert) (Entered: 04/02/2009) 
04/06/2009 
29 
r 
140.5 
KB 
Defendant's MOTION for Extension of Time to File Response as to 24 
MOTION to Consolidate Cases MOTION to Quash, 21 MOTION for 
Protective Order and to Quash Subpoena for Deposition of Jane Doe No. 4, 
Motion to Consolidate Cases for Purposes of Discovery, and Incorporated 
Memorandum of Law in Support by Jeffrey Epstein. (Pike, Michael) 
(Entered: 04/06/2009) 
04/07/2009 
30 
ENDORSED ORDER granting 29 Motion for Extension of Time to 
Respond re 24 MOTION to Consolidate Cases MOTION to Quash, 23 
MOTION for Protective Order and to Quash Subpoena for Deposition of 
Jane Doe No. 4, Motion to Consolidate Cases for Purposes of Discovery, 
and Incorporated Memorandum of Law in Support. Responses due by 
4/13/2009. Signed by Judge Kenneth A. Marra on 4/7/2009. (ir) (Entered: 
04/07/2009) 
04/10/2009 
31 
r 
137
KB
4 
Defendant's MOTION for Extension of Time to File Response as to 30 
Order on Motion for Extension of Time to File Response/Reply/Answer, 23 
MOTION for Protective Order and to Quash Subpoena for Deposition of 
Jane Doe No. 4, Motion to Consolidate Cases for Purposes of Discovery, 
and Incorporated Memorandum of Law in Support (Amended) by Jeffrey 
Epstein. (Pike, Michael) (Entered: 04/10/2009) 
https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?667278296697325-L_801_0-1 
6/10/2009 
EFTA00175255

CM/ECF,- Live Database - flsd 
Page 6 of 14 
04/13/2009 
32 
ENDORSED ORDER granting (73) Motion for Extension of Time to 
Respond re (66 in 9:08-cv-80119-KAM) MOTION for Protective Order 
and to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to 
Consolidate Cases for Purposes of Discovery, and Incorporated 
Memorandum of Law in Support in case 9:08-cv-80119-KAM; granting 
(65) Motion for Extension of Time to Respond re (66 in 9:08-cv-80119-
KAM) MOTION for Protective Order and to Quash Subpoena for 
Deposition of Jane Doe No. 3, Motion to Consolidate Cases for Purposes of 
Discovery, and Incorporated Memorandum of Law in Support in case 9:08-
cv-80232-ICAM; granting (80) Motion for Extension of Time to Respond re 
(66 in 9:08-cv-80119-ICAM) MOTION for Protective Order and to Quash 
Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate Cases 
for Purposes of Discovery, and Incorporated Memorandum of Law in 
Support in case 9:08-cv-80380-KAM; granting (31) Motion for Extension 
of Time to Respond re (66 in 9:08-cv-80119-KAM) MOTION for 
Protective Order and to Quash Subpoena for Deposition of Jane Doe No. 3, 
Motion to Consolidate Cases for Purposes of Discovery, and Incorporated 
Memorandum of Law in Support in case 9:08-cv-80993-KAM in case 9:08-
cv-80119-KAM. Responses due by 4/16/2009. Signed by Judge Kenneth A. 
Marra on 4/13/2009. (ir) (Entered: 04/13/2009) 
04/13/2009 
33 
r 
41.6 
KB 
Unopposed MOTION for Extension of Time to File 
Response /Memorandum in Opposition to Motion to Stay and/or Continue 
Action by Jane Doe No. 7. (Attachments: # 1 Text of Proposed Order) 
(Mermelstein, Stuart) (Entered: 04/13/2009) 
04/14/2009 
34 
ENDORSED ORDER granting (75) 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-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-ICAM) 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) 
Defendants MOTION to Stay re (56) Amended Complaint in case 9:08-cv-
80381-KAM; 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-ICAM) 
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) 
04/16/2009 
35 
Defendant's MOTION for Extension of Time to File Response as to 23 
MOTION for Protective Order and to Quash Subpoena for Deposition of 
https://ectflsd.uscourts.gov/cgi-bin/DktRpt.pl?667278296697325-L_801_0-1 
6/10/2009 
EFTA00175256

CWECF Live Database - flsd 
Page 7 of 14 
r
138.8 
KB
Jane Doe No. 4, Motion to Consolidate Cases for Purposes olDiscovery, 
and Incorporated Memorandum of Law in Support by Jeffrey Epstein. 
(Pike, Michael) Modified on 4/20/2009 (Is). (Entered: 04/16/2009) 
04/17/2009 
36 
ENDORSED ORDER granting (77) Motion for Extension of Time to 
Respond re (66 in 9:08-cv-80119-KAM) MOTION for Protective Order 
and to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to 
Consolidate Cases for Purposes of Discovery, and Incorporated 
Memorandum of Law in Support in case 9:08-cv-80119-ICAM; granting 
(84) Motion for Extension of Time to Respond re (66 in 9:08-cv-80119-
KAM) MOTION for Protective Order and to Quash Subpoena for 
Deposition of Jane Doe No. 3, Motion to Consolidate Cases for Purposes of 
Discovery, and Incorporated Memorandum of Law in Support in case 9:08-
cv-80380-KAM; granting (35) Motion for Extension of Time to Respond re 
(66 in 9:08-cv-80119-KAM) MOTION for Protective Order and to Quash 
Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate Cases 
for Purposes of Discovery, and Incorporated Memorandum of Law in 
Support in case 9:08-cv-80993-KAM in case 9:08-cv-80119-KAM. 
( Responses due by 4/24/2009). Signed by Judge Kenneth A. Marra on 
4/17/2009. (ir) (Entered: 04/17/2009) 
04/17/2009 
37 
n 
339.6 
KB 
RESPONSE to Motion re 23 MOTION for Protective Order and to Quash 
Subpoena for Deposition of Jane Doe No. 4, Motion to Consolidate Cases 
for Purposes of Discovery, and Incorporated Memorandum of Law in 
Support filed by Jeffrey Epstein. Replies due by 4/27/2009. (Pike, Michael) 
(Entered: 04/17/2009) 
04/17/2009 
38 
r 
42.2 
KB 
Unopposed MOTION for Extension of Time to File Response as to 27 
Defendant's MOTION to Compel Answers to 1st Interrogs, 26 Defendant's 
MOTION to Compel Response to 1st RTP by Jane Doe No. 7. 
(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 
04/17/2009) 
04/23/2009 
39 
r 
43.6 
KB 
RESPONSE in Opposition re 22 Defendant's MOTION to Stay re 19 
Amended Complaint filed by Jane Doe No. 7. (Mermelstein, Stuart) 
(Entered: 04/23/2009) 
04/27/2009 
40 
r 
50.3 
ica 
ORDER Granting 38 Unopposed Motion for Extension of Time to File 
Memorandum in Opposition to 27 Defendant's MOTION to Compel 
Answers to 1st Interrogatories, 26 Defendant's MOTION to Compel 
Response to First Request to Produce. Response due by 4/29/2009. Signed 
by Magistrate Judge Linnea R. Johnson on 4/27/2009. (sa) (Entered: 
04/27/2009) 
04/27/2009 
41 
r 
3j.j: 
MEMORANDUM in Support re 23 MOTION for Protective Order and to 
Quash Subpoena for Deposition of Jane Doe No. 4, Motion to Consolidate 
Cases for Purposes of Discovery, and Incorporated Memorandum of Law 
in Support by Jane Doe No. 7. (Mermelstein, Stuart) (Entered: 04/27/2009) 
https://ecf.flsd.uscourts.govicgi-bin/DIctRpt.p17667278296697325-L_801_0-1 
6/10/2009 
EFTA00175257

CIVWECF Live Database - flsd 
Page 8 of 14 
04/29/2009 42 
r 
60.2 
KB
ORDER granting 23 Motion for Protective Order and Consolidating Cases 
For Purposes of Discovery. Signed by Judge Kenneth A. Marra on 
4/28/2009. (cqs) (Entered: 04/29/2009) 
04/29/2009 
43 
r 
42.3 
KB 
Unopposed MOTION for Extension of Time to File Response as to 27 
Defendant's MOTION to Compel Answers to 1st lnterrogs, 26 Defendant's 
MOTION to Compel Response to 1st RTP by Jane Doe No. 7. 
(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 
04/29/2009) 
05/04/2009 
44 
r 
278.6 
KB 
MEMORANDUM in Opposition re 42 Order on Motion for Protective 
Order by Jeffrey Epstein. (Pike, Michael) (Entered: 05/04/2009) 
05/05/2009 
45 
r 
261.1 
KB 
RESPONSE TO ORDER TO SHOW CAUSE by Jeffrey Epstein. (Pike, 
Michael) (Entered: 05/05/2009) 
05/05/2009 46 
r 
sts 
KB 
Defendant's MOTION for Extension of Time to File Reply as to 39 
Response in Opposition to Motion to Stay by Jeffrey Epstein. (Pike, 
Michael) (Entered: 05/05/2009) 
05/05/2009 
48 
MOTION for clarification 42 Order on Motion for Protective Order by 
Jeffrey Epstein. Responses due by 5/22/2009. See image DE 45 (1k) 
(Entered: 05/06/2009) 
05/06/2009 47 
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 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-KAM; granting (46) 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-80993-
KAM; granting (37) 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-80994-KAM in case 9:08-ov-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 
49 
Clerks Notice of Docket Correction and Instruction to Filer re 45 Response 
to Order to Show Cause filed by Jeffrey Epstein. ERROR - Two or More 
Document Events Filed as One; Correction - Additional event(s) 48 
MOTION FOR CLARIFICATION docketed by Clerk. Instruction to Filer -
In the future, please select all applicable events. It is not necessary to refile 
https://ecf.flsd.useourts.gov/cgi-bin/DktRpt.p17667278296697325-L_801_0-1 
6/10/2009 
EFTA00175258

CM/ECF Live Database - flsd 
Page 9 of 14 
this document. (1k) (Entered: 05/06/2009) 
05/06/2009 
50 
r 
37.2 
KB
RESPONSE in Opposition re 27 Defendant's MOTION to Compel Answers 
to 1st Interrogs and for an Award of Reasonable Expenses filed by Jane 
Doe No. 7. (Horowitz, Adam) (Entered: 05/06/2009) 
05/06/2009 
51 
r 
340A 
KB 
RESPONSE in Opposition re 26 Defendant's MOTION to Compel 
Response to 1st RTP , Overrule Objections and for an Award of 
Reasonable Expenses filed by Jane Doe No. 7. (Attachments: # 1 Exhibit 
A)(Horowitz, Adam) (Entered: 05/06/2009) 
05/07/2009 
52 r 
84B
0.8
Defendant's MOTION to Compel and/or Identift Doe #7 in the Style of this 
Case and in Third-Party Subpoenas by Jeffrey Epstein. Responses due by 
5/26/2009 (Attachments: # .1_ Exhibit A)(Pike, Michael) (Entered: 
05/07/2009) 
05/07/2009 
53 
Alternative MOTION to Dismiss 1 Complaint by Jeffrey Epstein. 
Responses due by 5/26/2009. See image DE 52 (1k) (Entered: 05/08/2009) 
05/08/2009 
54 
Clerks Notice of Docket Correction and Instruction to Filer re 52 
Defendant's MOTION to Compel and/or Identifr Doe #7 in the Style of this 
Case and in Third-Party Subpoenas filed by Jeffrey Epstein. ERROR -
Motion with Multiple Reliefs Filed as One Relief; Correction -
Additional relief(s) 53 MOTION TO DISMISS docketed by Clerk. 
Instruction to filer - In the future, please select all applicable reliefs. It is 
not necessary to refile this document. (1k) (Entered: 05/08/2009) 
05/11/2009 
55 
r 
203.0 
KB 
Defendant's MOTION Require Plaintiff to Use Proper Case Style by 
Jeffrey Epstein. (Critton, Robert) (Entered: 05/11/2009) 
05/13/2009 
56 
r
400.3 
M3
RESPONSE/REPLY to 39 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 
57 
r 
1°63
Ica 
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-CIV-MARRA. Signed by Judge 
Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-ICAM et 
al. (ir) (Entered: 05/14/2009) 
05/14/2009 
58 
F 
:43
ORDER REQUESTING UNITED STATES PROVIDE POSITION TO 
MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009. 
(Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases: 
9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009) 
05/14/2009 
59 
ORDER denying as moot 48 Motion for Clarification; denying as moot 55 
https://ectflsd.uscourts.gov/egi-bin/DIctRpt.pl?667278296697325-L_801_0-1 
6/10/2009 
EFTA00175259

C14/ECF, Live Database - flsd 
Page 10 of 14 
Motion ; denying as moot 24 Motion to Consolidate Cases; denying as 
moot 24 Motion to Quash. See Order consolidating cases.. Signed by Judge 
Kenneth A. Marra on 5/14/2009. (Ic3) (Entered: 05/14/2009) 
05/14/2009 
60 
ORDER terminating 52 Motion to Compel; terminating 53 Motion to 
Dismiss; terminating 22 Motion to Stay. See Order consolidating cases. See 
procedural motions pending: DE 65 and DE 91 in 08-80119.. Signed by 
Judge Kenneth A. Marra on 5/14/2009. (1c3) (Entered: 05/14/2009) 
05/18/2009 61 r
174.3 
KB
Defendants MOTION for Extension of Time to File Reply as to (39 in 
9:08-cv-80994-KAM) 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-KAM et al.(Pike, Michael) (Entered: 
05/18/2009) 
05/19/2009 
62 
r 
MB
0.8
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) 
05/20/2009 
63 
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-KAM; 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-KAM; 
terminating (62) Motion to Strike in case 9:08-cv-80993-KAM; terminating 
(50) Motion to Strike in case 9:08-cv-80994-KAM. Signed by Judge 
Kenneth A. Marra on 5/20/2009. (1c3) (Entered: 05/20/2009) 
05/20/2009 
64 
Clerks Notice of Docket Correction and Instruction to Filer re 62 MOTION 
to Strike filed by Jeffrey Epstein. Error - Motion with Multiple Reliefs 
Filed as One Relief;. Instruction to filer - In the future, please select all 
applicable reliefs. It is not necessary to refile this document. (Is) (Entered: 
05/20/2009) 
05/20/2009 
65 
r 
363.1 
KB 
NOTICE by 
to Defendant, Jeffrey Epstein's Motion to Comp gi 
Or Ident
Identify
. of Filing Withdrawal of Previously Raised Oils 
in the Style of This Case and Motion to Identifri=. 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-KAM et al.(Hill, Jack) (Entered: 05/20/2009) 
05/20/2009 
66 
ORDER S 
G in all Epstein cases EXCEPT case no. 08-80119: 
Notice by 
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-KAM et al. (1c3) 
https://edflsd.uscourts.gov/egi-bin/DktRpt.pl?667278296697325-1.4_801_0-1 
6/10/2009 
EFTA00175260

CM/ECF'. Live Database - flsd 
Page 11 of 14 
(Entered: 05/20/2009) 
05/21/2009 
67 
r 
3KB
0.1 
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) 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-KAM et al. 
(Mermelstein, Stuart) (Entered: 05/21/2009) 
05/22/2009 
68 
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. Marra on 5/22/2009. (Ic3) (Entered: 
05/22/2009) 
05/22/2009 
69 
Clerks Notice of Docket Correction and Instruction to Filer re 65 Notice 
(Other), Notice (Other) filed by 
.. Error - Incorrect Document 
Link/No Link;. Instruction to filer - In the future, please link the document 
to the proper entry. It is not necessary to refile this document. (Is) (Entered: 
05/22/2009) 
05/27/2009 
70 
r
no 
KB
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-KAM) 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-KAM et al. 
(Horowitz, Adam) (Entered: 05/27/2009) 
05/28/2009 
71 
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 
72 
r, 
11.6 
KB 
NOTICE of Attorney Appearance by 
on behalf of 
Ilgilssaiftuaf America Associated Cases: 9:08-cv-80119-KAM et al. 
MM 
Me 
(Entered: 05/29/2009) 
, 
05/29/2009 
73 
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 
https://ectflsd.useourts.gov/cgi-bin/DktRptpl?667278296697325-1,_801_0-1 
6/10/2009 
EFTA00175261

CM/Eclz7 Live Database - flsd 
Page 12 of 14 
r
373 
KB
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) Defendant's MOTION to Stay re 
(19) Amended Complaint, (65 in 9:08-cv-80119-KAM) Defendant's 
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 re (40) Amended 
Complaint and or Continue Action Filed Pursuant to Court's Order 
Requesting Government's Position filed by United States of America. 
t
heAL6/8/2009. Associated Cases: 9:08-cv-80119-KAM et al. 
MM) 
(Entered: 05/29/2009) 
05/29/2009 
74 
r 
43.3 
KB 
RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's 
MOTION to Compel Identify Doe in Style of Case and in Third-Party 
Subpoenas, (91 in 9:08-cv-80119-KAM) Defendant's MOTION to Compel 
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-KAM et al.(Ezell, Katherine) (Entered: 05/29/2009) 
05/29/2009 
75 
ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in 9:08-
cv-80232-ICAM, 123 in 9:08-cv-80380-ICAM, 35 in 9:09-cv-80591-KAM, 
25 in 9:09-cv-80469-ICAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-
80656-KAM, 107 in 9:08-cv-80381-KAM) 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-KAM et al. (1c3) (Entered: 05/29/2009) 
05/29/2009 
76 
r
24.5 
KB
MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION 
TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, 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 
77 
r, 
19.5 
KB
MOTION for Hearing MOTION TO RESCHEDULE HEARING by Jane 
Doe No. 102, Jane Doe No. 101. Associated Cases: 9:08-cv-80119-KAM et 
al.(Josefsberg, Robert) (Entered: 05/29/2009) 
06/01/2009 
78 
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-ICAM, 77 in 9:08-
cv-80993-KAM, 38 in 9:09-cv-80591-ICAM, 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-KAM, 109 in 9:08-cv-80381-KAM, 
108 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv-
80380-KAM, 74 in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-KAM, 37 in 
hrips://ecf.flsd.uscourts.goviegi-bin/DktRptpl?667278296697325-L 801_0-1 
6/10/2009 
EFTA00175262

CM/ECF Live Database - flsd 
Page 13 of 14 
9:09-cv-80591-KAM, 107 in 9:08-cv-80811-KAM, 27 in 9:09-cv-80469-
ICAM) 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. (1c3) (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 
79 
r 
349.0 
KB
REPLY to Response to Motion re (113 in 9:08-cv-80119-KAM) 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) 
06/04/2009 
80 
ORDER STRIKING (112 in 9:08-cv-80381-KAM, 111 in 9:08-cv-80232-
KAM, 136 in 9:08-cv-80119-KAM, 111 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-ICAM, 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 
81 r
3.8 
MB
RESPONSE to Motion re (91 in 9:08-cv-80119-KAM) 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-ICAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/08/2009 
82 
r 
mil l
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 of Joinder Associated 
Cases: 9:08-cv-80119-ICAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/09/2009 
83 
r 
Ma
Unopposed MOTION to Amend/Correct 28 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 OrderXPike, 
Michael) (Entered: 06/09/2009) 
https://ecf.flsd.useourts.gov/egi-bin/DktRpt.pl?667278296697325-L_801 0-1 
6/10/2009 
EFTA00175263

CWEC
IF 
T Live Database - flsd 
Page 14 of 14 
06/10/2009 
84 
ENDORSED ORDER granting 83 Motion to Amend affirmative defenses. 
Defendant must separately file affirmative defenses. Signed by Judge 
Kenneth A. Marra on 6/9/2009. (ir) (Entered: 06/10/2009) 
06/10/2009 
85 
Clerks Notice of Docket Correction and Instruction to Filer re 82 Notice 
(Other), Notice (Other) filed by Jane Doe. Error - Wrong Event Selected;. 
Instruction to Filer - In the future, please select the proper event, i.e. Notice 
of Adoption. It is not necessary to refile this document. (Is) (Entered: 
06/10/2009) 
06/10/2009 
86 
r
o.s 
MB 
AMENDED DOCUMENT by Jeffrey Epstein. Amendment to 19 Amended 
Complaint, 28 Answer to Amended Complaint. (Pike, Michael) (Entered: 
06/10/2009) 
or 
View Selected 
Download Selected 
Total filesize of selected documents (MB):1 
Maximum filesize allowed (MB): 10 
PACER Service Center 
Transaction Receipt 
06/10/2009 14:04:28 
PACER 
Login: 
du4480 
Client Code: 
Description: 
Docket 
Report 
Search 
Criteria: 
9:08-cv-809931
KAM 
Billable 
Pages: 
9 
Cost: 
0.72 
https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p17667278296697325-L_801_0-1 
6/10/2009 
EFTA00175264

Case'9:09-cv-80469-KAM 
Document 1 
Entered on FLSD Docket 03/25/2009 RIPON 
 1 105 
 0.1 
ELECTRONIC 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Mar. 24, 2009 
STEVEN m.LARim0RE 
CLERK N.S. DIST. CT. 
s.o. Or FLA.• MIAMI 
09-80469-Civ-RYSKAMPNITUNAC 
JANE DOE II 
) 
CASE NO.: 
) 
Plaintiff, 
) 
) 
vs. 
) 
) 
an
P 
) 
and 
) 
) 
Defendants. 
) 
COMPLAINT 
1. 
Plaintiff, JANE DOE II, hereby sues JEFFREY EPSTEIN and 
and states: 
JURISDICTION AND VENUE 
2. 
This is an action for damages in excess of $75,000, exclusive of interests, 
costs and attorney's fees. 
3. 
Venue is proper in this Court as all acts occurred in Palm Beach County and 
all parties reside and/or do business herein. 
PARTIES 
4. 
Ms. DOE II is a natural person residing in Palm Beach County, Florida. During 
the events giving rise to this claim, she was a minor but has now reached majority. She files 
this suit under a pseudonym to protect her privacy because the acts alleged occurred while 
she was a minor. 
SCANNED
I oil 
EFTA00175265

O9-.110: 199sLiwERYSKIA rtIRLIATE N A a
.red 
on FLSD Docket 03/25/2009 
Page 3 of 5 
•
 
11. 
From about June, 2003 until on or about February, 2005, Defendants 
EPSTEIN anal 
persuaded, induced, or enticed the Plaintiff to come to Defendant 
EPSTEIN's home and provide Defendant EPSTEIN with "massages". which escalated into 
sexual encounters between Defendant EPSTEIN and the Plaintiff designed to fulfill his 
unnatural sexual desires for young women or even younger girls who were minors. These 
acts included Defendant EPSTEIN's request that he wanted the encounter to be like a 
"porn video." Defendant EPSTEIN would script lines for the Plaintiff to say, including calling 
out his name and requesting that he perform a certain sexual act "harder,"while he touched 
the Plaintiffs aor 
with 
alternately, he would min 
the presence of the Plaintiff after demanding her to disrobe and walk in front of him in 
provocative sexual poses. Defendant EPSTEIN would pay the Plaintiff a fee of $200 on 
each occasion after he 
while 
in the presence of the Plaintiff. 
12. 
Defendant EPSTEIN touched Plaintiffs 
, or 
Plaintiffs 
on multiple occasions, during the time that 
Plaintiff was a minor, causing personal injury to her. 
13. 
In violation of 18 U.S.C. §2422(b),Defendants EPSTEIN and 
knowingly persuaded, induced, or enticed the Plaintiff to engage in acts of prostitution, when 
the Plaintiff was under the age of 18, approximately on or about the following dates that 
Plaintiff can document based on payments received: 6/16/03, 7/2/03, 4/9/04, 6/7/04, 
7/30/04, 8/30/04,10/9/04, 10/12/04, 10/30/04 and 11/9/04. In addition, Plaintiff believes that 
there were as many as 10 to 20 other occasions during this time frame that Defendant 
EPSTEIN solicited her and procured her to perform prostitution services, all during the time 
that she was a minor. 
3 
3 of 
EFTA00175266

09-80As69.aiMr-ROYSOAMPAY3MINAC Entered on FLSD Docket 03/25/200 FILEAN 51bP5 S. 
ELECTnoW 
ims 44 Mao. 204/ 
CIVIL COVER SHEET 
ThelS 44 civil coyeuheet and the information omnibus' herein neither resdne nor supplement the ft/Mgand service of pleadings or other papers 
by local mks of coon. This Ranh approved by the Judicial Conference of the UnitedSrates in September 1974, is required for the use of the Clerk 
the civil docket sheet. (SEE INSTRUCT/OHS ON THE REVERSE OP THE reit 
NOTICE: Attorneys MUST Indicate All Re-filed 
I. (a) PLAINTIFFS 
DEFENDANTS 
JANE DOE II 
(b) County of Residence of Finn Listed Plaintiff PALM BEACH 
(EXCEPT IN U.S. PLAINTIFF CASES) 
Al0301tri IMRE N464. Addles.. M 
TeNple444 Neraber) 
GARCIA LAW FIRM, P.A. 
224 DATURA STREETM SUITE 900 
WEST PALM BEACH, FL 33401 
JEFFREY EPSTEIN ANC 
I KELL 
Mar. 24, 2009 
STEVEN M. LARIMORE 
CLERK U.S• DIET. GT. 
5.0. OF FLA. • MIAMI 
County of Residence of First Listed Defendant 
PALM BEACH 
(IN U.S. PLAINTIFF CASES ONLY) 
NOTE: IN LAND CONDEMNATION CASES. USE THE LOCATION OF THE TRACT 
LAND INVOLVED. 
/1110010). OFE444310 
ROBERT D. CRITTON, ESQ. 
JACK A. GOLDBEROER, ESQ. 
O 
141) Check Canty Whom ACA1011M03* 0 MIAMI. DADE 3 Mumma 0 IROWARD tO PALM SEAN 3 MARTIN 
0 ST. LUCIE 3 INDIAN RIVER 
1 OKEECHOBEE 
HIGHLANDS 
II. BASIS OF JURISDICTION 
(Plan en cr loom snow 
O I 
U.S. 00Mtnalent 
Vb3 
Fodefel Queellea 
Plaintiff
44 
00Velalnent Net • Poly) 
c/ 1 U.S. Dawrnmenl 
I 
1 
D1vemhy 
(I West ChitcroMp of 
rein In IMm III 
0111.41'"
09
CV geoL)69 
Ate 
III. C TIZENSIIIP OF PRINCIPAL PARTI ES(png. 'Cr 
in 0.{ On lot ?Wolff 
rot DI/malty Cam Oaily) 
osad Om Him for Defenden0 
PTF 
OEr 
ITF 
DEF 
CIOan Of VIII AMC 
0 
I 
0 
I 
Incorpotated or Principal flee 
3 
4 
04 
of Badman In This Sale 
C Mien of An cam Stale 
0 
2 
0 
2 
Incorporated and Pritcoal Plate 
3
5 
of fliameas la Another Mole 
Ckiirc 01 S objec i of a 
0 
n 
rOlOilnNnlon 
1 
6 
1 
Co array 
IV. NATURE OF SUIT 4lnt Ser XTh Qt4 BO* 
1 
CONTRACT 
TORTS 
FORFEITURE/PENALTY 
11ANKRIIPTCY 
OTHER STATUTES 
I 
3 110 Inatome 
0 120 Meilne 
O 130 Millet AO 
3 140 Nesoilable lastrument 
CI ISO Recovery a Oreepaymest 
A EAROICONPIAI of Migmeni 
S I SI MOEN, Alt 
0131 Recowty of Dersulted 
student LAO. 
leael Enemas) 
O 13) Recovery of0worpsyrnenl 
of Vciaran's Benefits 
O 160 Sloe Ittolden' Suits 
1 190 Orbit Conueo 
0 193 Ce nom Paothon Liability 
3 196 Fraachlor 
PERSONA L INJURY 
0 MO Alephae 
3 )13 Alephise ***** ct 
1.1014117 
0320 Amish. Label A 
SI 44444 
0 330 Federal Employer.' 
Llehllity 
0 140 Mmiso 
0 343 Metioe Note; 
Mainly 
0 330 Moine VOW* 
0 333 Moser Vehicle 
1046•0 LIMINry 
II )60 0 dam Penomil 
14 40 
PERSONAL INJURY 
0 
362 Poreoftel Injury • 
M ed. 14•Ipeseibm 
IT 
363 Personellofury • 
Peeducl LIONly 
0 
MI AsMoNs !Mad 
Injury hodocl 
Liability 
PERSONAL PROPERTY 
0 
370 Other fend 
0 
371 Troth la LetdIM 
3 
310 Oast/snood 
PlOpetty Dunn 
0 
MI Property Demote 
MotoI Lisbilky 
0 
610 ',Pinhole 
0 
620 Oaer Food A; Drat 
0 
613 Dros Related Se Hum 
of Formeety )1 USC III 
0 
630 LIquot Lan 
0 
440 R.R. • Mask 
0 
630 Maim Rqs. 
0 
660 OecuPallooel 
StRity/Holth 
0 
690 004f 
002 K190124 ESC 124 
11 423 WIthdrsool 
24 USC 01 
0 
400 Slat Realmoitionmem 
3 
410 AnIlifint 
0 
4)0 gaols and Benlcog 
0 
00Comment 
0 
444 Doperteilon 
0 
4/0 Racketeer Inlloroce. and 
COHEN Omenhations 
3 
4141Contoner Credit 
0 
4441C414./Set TV 
/ 
III Sako6.3 Sankt 
040 SmesekinCommodiCom 
Emboss. 
3 03 ConnateChilliest 
12 USC 1410 
0 
44400w. Sletoloiy Atibas 
3 
$91 Asiicolvesal Am 
0 
MIT Ecoomek Shibilismim AO 
0 
493 EnaOninISIIII A1•1100 
2 IN Energy A Botafton A ei 
3 MI PreSom of Infonossioe AO 
0 140 ApRelll of Fee Dmenekstion 
1.1444rE440 Muss to Auk* 
0  1111Commutionality of Slew 
Simms 
I PROPERTY RIGHTS 
0 00 Coorleaes 
0 041Faleat 
0 SMITrataork 
LABOR 
SOCIAL SECURITY 
3 
710 441e taw Santa* 
Acl 
0 
720 laboeiMpel. Radom 
0 
730 labotIMEentlepoelin$ 
a Damloswe Am 
0 
710 114114.3. Leber All 
0 
790 004/ labor Litigation 
0 
791 Cool. Eel. Inc. Staudt) 
Acl 
0 $61 NIA ()363M 
0442 Meek Lam (923) 
0463 DIMC/DIWW (403(p)) 
0 064 010 Mk XVI 
0 503 est W(n1 
i 
REAL PROPERTY 
CIVIL RIGHTS 
rations PETITIONS 
FEDERAL TAX SUITS 
3210 Lead C 004e41104 MO 
0 220 FDICel ttttt 
1 2)0 Rent Lam A Efroomat 
0 240 Tone M L eed 
0 245 Tort Prod& LlabIllry 
3 290 Al Otheir Real Properly 
0 441 Voting 
0 442 Isoploymeat 
0 443 llotoMM 
Aesommodillone 
0 444 Wolfs,* 
.. 443 Anil. 
fDisabllitioe • 
la 
w 
taistramt 
0 446 ARM. w/DIseb0200; i
Other 
0 440 Other Clod R Mho 
0 
310 Modem en %Mem 
Soong 
Hahne Cogent 
0 
3)0 Omen! 
0 
035 Dolk Ponaky 
0 
340 Mandamus A 06.0 
0  
030 era, S wis
0 
333 Pelson Condition 
0 III Tame N.S. Pleloillf 
Or ElsfeadaM) 
0 III IRS—Thh4 Pluly 
26 USC 7609 
I 
•MM7C 0 anon 
462 Nueoliniko 
0 
Applkailon 
0  463 Hams ColowoAllon 
De41019 
0 
A42  Other Iminigniloo 
V. ORIGIN 
(Ileco a 
—X' In Om Box Omit) 
fT / Original 
7 2 Removed from 
Ill 3 
Re.liled. 
Proceeding 
State Cain 
Dee VI below) 
O 4 Reinstated Or O 
Reopened 
Trans erred from 
S another district 
" 
6
(speedy) 
VI. RELATED/RE-FILED 
CASE(S). 
(Set Instemiloss 
snood rim): 
a) Re-filed Case OYES ONO 
JUDGE 
Multidistriet 
O 7 
Litigation 
b) Related Caeca (WES ONO 
DOCKET NUMBER 9 :at -cv -2o)(A-Icissi 
Appeal to District 
Jute from 
Magistrate 
Martian 
VII. CAUSE OF ACTION 
CI c the US. Civil Statute under which you am fdmg and Write a Strict &Inerrant of Cause (Do not cite larbdiellonal statutes °Mos 
diversity): 
IS US.C. §2422(b) 
LENGTH OF TRIAL via 
days estimated (for both sides to ity wins case) 
VIII. REQUESTED IN 
COMPLAINT: 
CHECK WM 
A CLASS Amor,' 
UNDER 
23 
ABOVE INFORMATION IS TRUE & CORRECT TO 
THE BEST OF MY KNOWLEDGE 
1011A 
EMAND S 
ClIECK YES only if dern
in commisint 
JURY DEMAND: 
VYes RI No 
EY OF RECORD 
DATE 
March 19, 2009 
FOR 0 rt E USX ONLY 
AMOUNT 
lifil6RECEIPT a 7.17(51G9te 
EFTA00175267

Case 9:09-cv-80469-KAM 
Document 31 
Entered on FLSD Docket 06/01/2009 
Page 1 of 11 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 09-CIV- 80469 - MARRA/JOHNSON 
JANE DOE II, 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
/ 
DEFENDANT EPSTEIN'S REPLY TO & MOTION TO STRIKE PORTIONS OF PLAINTIFF'S 
MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT'S MOTION TO DISMISS 
Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned 
attorneys, replies to and moves to strike Point 4 of Plaintiff's Memorandum Of Law In 
Opposition To Defendant Epstein's Motion To Dismiss, dated May 22, 2009, ("MOL"). 
Accordingly, Defendant states: 
I. Legal Standard (pp. 1-2 of Plaintiff's MOLI 
Plaintiff's reliance on Conley v. Gibson, 355 U.S. 41, 45-46 (1957), as the Rule 
12(b)(6) pleading standard is misplaced. 
As discussed in Defendant's motion to 
dismiss, (pp. 16 - 17), the standard as detailed in Bell Atlantic Corp. V. Twomblv, 127 
S.Ct. 1955 (2007), Is now the applicable standard, not Conley. Although the complaint 
need not provide detailed factual allegations, the basis for relief 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." Twomblv, at 1965. Further, "fflactual 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. The United States 
Supreme Court very recently made clear in Ashcroft v. lubal No. 07-1015 (U.S. May 18, 
EFTA00175268

Case 9:09-cv-80469-KAM 
Document 31 
Entered on FLSD Docket 06/01/2009 
Page 3 of 11 
Jane Doe II v. Epstein, et al. 
Page 3 
counter and does not appear to directly dispute Defendant's position that the state court 
would have concurrent jurisdiction over the claim brought pursuant to 18 U.S.C. §2255. 
Secondly, Plaintiff's assertion, (MOL, p.2, fn. 1), that it is somehow improper to 
attach a copy of this same Plaintiff's Complaint from the state court proceeding in 
support of Defendant's motion is ridiculous. It is completely proper and in essence 
required of any party to give notice to a court of a related pending proceeding. (See for 
example, Loc. Gen. Rule 3.8 (S.D. Fla. 2009).' The fact that there does exists a 
previously filed action by Plaintiff against Defendant is directly relevant to this Court's 
decision of whether or not to exercise jurisdiction over the §2255 claim when there 
exists a previously filed proceeding in which the claim might also be brought. Needless 
to say, whether or not a Court exercises jurisdiction over a matter is a critical issue. 
Finally, Plaintiff completely mischaracterizes what she herself alleged in 
paragraph 15 of her Complaint. In her MOL, p. 7, Plaintiff falsely asserts that in par. 15 
she "pled that Defendant made an agreement with the United States Attorney's Office to 
not contest the jurisdiction of this Court in exchange for avoiding prosecution under 
federal law for solicitation of minors for prostitution." What is actually alleged in par. 15 
is the following: "Defendant EPSTEIN has made an agreement with the United 
States Attorney's Office to not contest liability for claims brought exclusively 
'See also Bray & Gillespie Management LLC v. Lexington Ins. Co., 2008 WL 4826115, 1 (M.D. 
Fla. 2008) — "Wile Court 'may take notice of proceedings in other courts, both within and without 
the federal judicial system, if those proceedings have a direct relation to matters at issue.' St. 
Louis Baptist Temple, Inc. v. FDIC, 605 F.2d 1169, 1172 (10th Cir.1979); accord Coney v., 
Smith, 738 F.2d 1199, 1200 (11th Cir.1984). Counsel should be given notice of and an 
opportunity to be heard as to the propriety of taking judicial notice. Fed.R.Civ.P. 201(e)." Here, 
Plaintiff filed the state court action and is, thusly, well of aware of its existence and details. 
EFTA00175269

Case 9:09-cv-80469-KAM 
Document 31 
Entered on FLSD Docket 06/01/2009 
Page 5 of 11 
Jane Doe II v. Epstein, et al. 
Page 5 
does not provide for a multiplier and speaks in terms of "personal injury" suffered and 
"actual damages." 
Supporting the fact that Defendant properly raised these issues in his motion to 
dismiss are the allegations set forth in Plaintiff's complaint. In paragraph 11, Jane Doe 
II alleges that — "From about June, 2003 until about February, 2005, Defendants, 
EPSTEIN and 
persuaded, induced, or enticed Plaintiff to come to Defendant 
EPSTEIN's home and provide Defendant EPSTEIN with 'massages' ... ." In paragraph 
13, Plaintiff further alleges — "In violation of §2422(b), Defendants EPSTEIN and 
knowingly persuaded, induced, or enticed the Plaintiff to engage in acts of 
prostitution, when the Plainitff was undr the age of 18, approximately on or about the 
following dates that Plaintiff can document based on payments received: 6/16/03, 
7/2/03, 4/9/04, 6/7/04, 7130/04, 8/30/04, 10/9/04, 10/12/04 and 11/9/04. 
." 
In 
paragraph 14, Plaintiff alleges — "Plaintiff seeks damages for personal injury in 
accordance with 18 U.S.C. §2255(a) for each of the acts of prostitution set forth above 
which Defendants solicited her, $150,000 for each violation, for a total range of 
damages between $1.5 million dollars and $4.5 million dollars, jointly and severally, and 
a reasonable attorney's fees and costs, as permitted by the statute." 
Plaintiff chooses to analyze whether the statute in effect at the time of the alleged 
conduct or the amended statute applies under a procedural versus substantive analysis. 
Plaintiff, in short, argues that "the change in the civil remedies available of a statute is a 
procedural, not a substantive change in the law, and procedural changes to a statute 
are routinely applied retroactively." (MOL, p. 9). Clearly , the change to the statute was 
EFTA00175270

• 
Case 9:09-cv-80469-KAM 
Document 31 
Entered on FLSD Docket 06/01/2009 
Page 7 of 11 
Jane Doe II v. Epstein, et al. 
Page 7 
quoting as it confirms and supports that an amendment to a statute, such as in the 
instant case — increasing the penalty or liability for damages by at least triple fold, or 
under Plaintiffs analysis, by 90 times from $50,000 to $4.5 million! - and with no 
expression that it is to apply retroactively — will not be interpreted to apply retroactively. 
Congress may prescribe the temporal reach of a statute by stating that it 
applies to pre-enactment conduct, the first step in the Landgraf analysis, or a 
statute may be silent regarding temporal reach, in which case courts 
apply tho judicial presumption against retroactivity. This presumption and 
analysis, however, are unwarranted when Congress states its unambiguous 
intention that the statute apply retroactively to pre-enactment conduct, in 
language comparable to § 1658(b), that the new or amended statute applies to 
proceedings commenced on or after enactment. See Landgraf, 511 U.S. at 259-
60, 114 S.Ct. at 1494 (stating that, if had Congress intended retroactive 
application, then "it surely would have used language comparable to ... 'shall 
apply to all proceedings pending on or commenced after the date of enactment' 
") (citation omitted); accord INS v. St. Cyr, 533 U.S. 289, 318-19 & n. 43, 121 
S.Ct. 2271, 2289-90 & n. 43, 150 L.Ed.2d 347 (2001) (collecting examples of 
unambiguous temporal statutory language providing that the statute applies to 
actions filed "on or after" the date of enactment, which includes violative 
conduct that occurred prior to the effective date of the statute); Martin v. Hadix, 
527 U.S. 343, 354, 119 S.Ct. 1998, 2004, 144 L.Ed.2d 347 (1999) (stating that " 
'new provisions shall apply to all proceedings pending on or commenced after 
the date of enactment,' " referenced in Landgraf, "unambiguously addresses the 
temporal reach of the statute" (citation omitted)); Lindh v. Murphy, 521 U.S. 
320, 329 n. 4, 117 S.Ct. 2059, 2064 n. 4, 138 L.Ed.2d 481 (1997) (recognizing 
from Landgraf that statutory language such as, " `[This Act] shall apply to all 
proceedings pending on or commenced after the date of enactment of this Act,' 
" "might possibly have qualified as a clear statement for retroactive effect" 
(quoting Landgraf, 511 U.S. at 260, 114 S.Ct. at 1494)); Rivers v. Roadway 
Express, Inc., 511 U.S. 298, 307-08, 114 S.Ct. 1510, 1517, 128 L.Ed.2d 274 
(1994) (noting that the subject statute omitted a provision in the bill that the 
amendment "'shall apply to all proceedings pending on or commenced after' " a 
fixed date and describing the bill as containing "express retroactivity 
provisions"). ... 
Unlike other statutory enactments or amendments (cited above) where Congress 
unambiguously expressed its intent regarding retroactive application, there is no 
expression with respect to Masha's Law, the 2006 amended version of §2255. An 
EFTA00175271

Case 9:09-cv-80469-KAM 
Document 31 
Entered on FLSD Docket 06/01/2009 
Page 9 of 11 
Jane Doe II v. Epstein, et al. 
Page 9 
discussed in Part III, A. of Defendant's motion to dismiss, unlike other statutes, there is 
absolutely no language in the statute that suggest that the presumptive damages 
amount is subject to multiplication on a per violation/incident basis. The statute on its 
face speaks in terms of "actual damages" and "personal injury suffered." 
The recent case of United States v. Berdeal, 595 F.Supp.2d 1326 (S.D. Fla. 
2009), further supports Defendant's argument that the "rule of lenity," (Part. ■. 
of 
Defendant's motion), requires that the Court resolve the statutory interpretation conflict 
in favor of Defendant. 
Assuming for the sake of argument that Plaintiff's multiple 
causes of action, leading to a multiplication of the statutory damages amount, is a 
reasonable interpretation, like Defendant's reasonable interpretation, under the "rule of 
lenity," any ambiguity is resolved in favor of the least draconian measure. In Berdeal,
applying the rule of. lenity, the Court sided with the Defendants' interpretation of the 
Lacey Act which makes illegal the possession of snook caught in specified jurisdictions. 
The snook had been caught in Nicaraguan waters. The defendants filed a motion to 
dismiss asserting the statute did not encompass snook caught in foreign waters. The 
United States disagreed. Both sides presented reasonable interpretations regarding the 
reach of the statute. In dismissing the indictment, the Court determined that the rule of 
lenity required it to accept defendants' interpretation. 
Point 4. Point 4 is required to be stricken as Plaintiff attempts to argue facts not 
alleged In the Complaint, and misrepresents what is alleged in the Complaint. 
Point 4 of Plaintiff's MOL, p. 15-17, is required to be stricken as it not only argues 
facts outside of the four corners of the complaint, but it continues to misrepresent what 
is actually alleged In paragraph 15 of Plaintiffs complaint. See discussion under "Point 
EFTA00175272

Case 9:09-cv-80469-KAM 
Document 31 
Entered on FLSD Docket 06/01/2009 
Page 11 of 11 
Jane Doe II v. Epstein, et al. 
Page 11 
Isidro M. Garcia, Esq. 
Garcia Law Firm, P.A. 
224 Datura Street, Suite 900 
West Palm Beach, FL 33401 
F 
isidrogarcia(a:bellsouth.net 
Counsel for Plaintiff 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
ch, FL 33401-5012 
Fax 
jaqesaabellsouth.net 
Co-Counsel for Defendant Jeffrey Epstein 
Respectful) 
By: 
ROBERT D. RITTON, JR., ESQ. 
Florida Bar o. 224162 
reritAbcicl w.com 
MICHAEL J. PIKE, ESQ. 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 N. Flagler Drive, Suite 400 
ch, FL 33401 
Fax: 
(Co-counsel for Defendant Jeffrey Epstein) 
EFTA00175273