EFTA00175214

CM/Eer - Live Database - flsd 
Page 9 of 9
in the Alternative, for a More Definate Statement. Responses due by 
6/26/2009. Page limit is set at 36 pages. Signed by Judge Kenneth A. Marra 
on 6/9/2009. (ir) (Entered: 06/10/2009) 
06/10/2009 
50 
Clerks Notice of Docket Correction and Instruction to Filer re 45 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) 
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https://ecf.flsd.uscourts.gov/cgi-bin/DlaRpt.p17716393569552562-L_801_0-1 
6/10/2009 
EFTA00175314

Case 9:08-cv-80811-KAM 
Document 113 
Entered on FLSD Docket 06/05/2009 
Page 1 of 4 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON 
Plaintiff, 
VS. 
Y 
EPSTEIN and 
Defendants. 
PLAINTIFF, M.'S, CONDITIONAL NOTICE OF INTENT TO EXCLUSIVELY RELY 
ON STATUTORY DAMAGES PROVIDED BY 18 U.S.C. 42255 
Plaintiff, 
, by and through her undersigned counsel, hereby files her 
Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided by 18 
U.S.C. §2255, and in support thereof states as follows: 
1. 
This is an action to recover money damages against Defendant, 
JEFFREY EPSTEIN, for acts of sexual abuse and prostitution committed upon the then-
minor, 
2. 
Plaintiff has plead thirty separate counts against EPSTEIN for separate 
incidences of abuse committed by EPSTEIN against Plaintiff pursuant to 18 U.S.C. 
§2255. 18 U.S.C. §2255, entitled "Civil remedy for personal injuries", creates a private 
right of action for minor children who were the victim of certain enumerated sex 
offenses. 18 U.S.C. §2255 also creates a statutory floor for the amount of damages a 
EFTA00175315

Case 9:08-cv-80811-KAM 
Document 113 
Entered on FLSD Docket 06/05/2009 
Page 2 of 4 
victim can recover for a violation of same. Plaintiff has also alleged a single count of 
Sexual Battery against EPSTEIN as well. 
3. 
There presently exists between the Plaintiff and EPSTEIN a disagreement 
as to whether the statutory damage floor established in 18 U.S.C. §2255 is recoverable 
for each commission of an enumerated sex offense listed in 18 U.S.C. §2255, or 
whether the statutory damage floor can only be enforced once, regardless of how many 
times a defendant perpetrates an enumerated sex offense against a minor victim. 
4. 
This disagreement between the parties is properly the subject of 
Defendant's Motion to Dismiss First Amended Complaint For Failure to State a Cause 
of Action, and Motion For More Definite Statement; Motion to Strike, and Supporting 
Memorandum of Law (D.E. 47) which is currently pending before this Court. 
5. 
In the event that the Court rules that the Plaintiff is entitled to recover the 
statutory damages created by 18 U.S.C. §2255 for each violation', Plaintiff will be 
pursuing only those statutory damages, and will not pursue damages available at 
common law. 
6. 
Should the Court rule however, that the statutory damage floor can only 
be applied once, Plaintiff will be pursuing any and all damages available to her, whether 
they be pursuant to statute or by common law. 
I The parties also disagree about the amount the statutory damage floor should be for this case. 18 
U.S.C. §2255 was amended In 2006 to Increase the floor from $50,000 to $150,000. The parties 
essentially disagree about which version of 18 U.S.C. §2255 should apply in this case. 
EFTA00175316

Case 9:08-cv-80811-KAM 
Document 113 
Entered on FLSD Docket 06/05/2009 
Page 3 of 4 
Respectfully submitted, 
/c/.lank P Hill 
JACK SCAROLA 
Florida Bar No. 169440 
JACK P. HILL 
Florida Bar No.: 0547808 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach. 
409 
Phone: 
Fax: 
Attorneys for Plaintiff, 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on June 5th, 2009, I electronically filed the foregoing 
document with the Clerk of Court using CM/ECF. I also certify that the foregoing 
document is being served this day on all counsel of record identified on the attached 
counsel list via transmission of Notices of Electronic Filing generated by CM/ECF. 
tqllnck P Hill 
JACK SCAROLA 
Florida Bar No. 169440 
JACK P. HILL 
Florida Bar No.: 0547808 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Bearh Florida 33409 
Phone: 
Fax: 
Attorneys for Plaintiff, 
EFTA00175317

Case 9:08-cv-80811-KAM 
Document 113 
Entered on FLSD Docket 06/05/2009 
Page 4 of 4 
COUNSEL LIST 
Jack A. Goldberger, Esquire 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue S. 
West Palm Beach FL 33401 
Phone: 
Bruce E. Reinhart, Esquire 
Bruce E. Reinhart, P.A. 
250 South Australian Avenue 
Suite 1400 
West Palm Beach FL 33401 
Phone: 
Fax: 
Robert Critton, Esquire 
Burman Critton Luttier & Coleman LLP 
515 North Flagler Drive, Suite 400 
West Palm Beach FL 33414 
Phone: 
Fax: 
Richard H. Willits, Esquire 
Richard H. Willits, P.A. 
2290 10th Avenue North 
Suite 404 
Lake Worth, FL 33461 
Phone: 
Fax: 
EFTA00175318

Case 9:08-cv-80811-KAM 
Document 35 
Entered on FLSD Docket 01/07/2009 
Page 1 of 7 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80811-MARRA/JOHNSON 
v. 
Plaintiff, 
JEFFREY EPSTEIN and 
Defendants, 
DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS 
COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION 
Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned 
counsel, moves to dismiss Count I of Plaintiffs Complaint for failure to state a cause of 
action. Rule 12(b)(6), Fed.R.Civ.P. (2008). Count II is directed only to Defendant 
who has not yet been served. In support of dismissal, Defendant states: 
Plaintiff, 
, attempts to assert a cause of action against EPSTEIN in Count I 
of her Complaint. A review of the inadequate Complaint allegations establishes that 
Plaintiff has failed to state a cause of action under either common or statutory law, and 
thus, Count I against EPSTEIN is required to be dismissed. Rule 12(b)(6), Fla.R.Civ.P. 
Count I alleges in part that while Plaintiff was a minor, beginning when she was 14 — 
6. On numerous occasions ..., JEFFREY EPSTEIN intentionally induced 
and/or seduced the Plaintiff into performing various acts of lewd and lascivious 
conduct and/or sexual performances in his presence. ... 
7. On numerous occasions ..., JEFFREY EPSTEIN performed various acts of 
lewd and lascivious conduct in the presence of the Plaintiff. ... 
EFTA00175319

Case 9:08-cv-80811-KAM 
Document 35 
Entered on FLSD Docket 01/07/2009 
Page 2 of 7 
v. Epstein, et al. 
8. On numerous occasions ..., JEFFREY EPSTEIN touched the Plaintiff's 
breasts and genitilia. 
9. As a result, the Plaintiff suffered mental anguish, mental pain and suffering, 
psychic trauma, and a loss of the capacity for the enjoyment of life. 
(Plaintiff alleges in her Complaint, ¶2, that she is presently 21 years old. The suit 
was originally filed in Florida state court, Palm Beach County Circuit Court, on February 
21, 2008.) 
Count I is lacking in sufficient factual allegations to allege the necessary 
elements to state a cause of action either under common or statutory law. In fact, 
Count I fails to allege any recognizable elements. There is absolutely no reference in 
Count I as to whether Plaintiff is attempting to assert some type of common law cause 
of action or as to whether she is relying on some type of Federal or State of Florida 
statute that might give rise to a civil cause of action. In addition, the Complaint 
generally alleges that "on numerous occasions," as opposed to alleging specific dates 
and times. 
Finally, the Complaint very generally references "lewd and lascivious 
conduct and/or sexual performances" without any underlying factual allegations. 
Accordingly, Count I is subject to dismissal for failure to state a cause of action. 
Supporting Memorandum of Law 
Rule 12(b)(61 Motion To Dismiss 
As established by the Supreme Court in Bell Atlantic Corp. V. Twomblv, 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 
in the complaint must state "more than labels and conclusions, and a formulaic 
EFTA00175320

Case 9:08-cv-80811-KAM 
Document 35 
Entered on FLSD Docket 01/07/2009 
Page 3 of 7 
. v. Epstein, et at 
0,3 
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. M.T.V. v. DeKalb County 
Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006). 
Significantly, the Supreme Court in Bell Atlantic Corp. V. 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 no set of facts in 
support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley 
v. 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) motion to dismiss does not 
need detailed factual allegations, ibid.; Sanivag.i. American Bd. of 
Psychiatry and Neurology, Inc., 40 F.3d 247, 251 1..7 19941, a plaintiffs 
obligation to provide the "grounds" of his "entitle[ment] to relief' requires 
more than labels and conclusions, and a formulaic recitation of the elements 
of a cause of action will not do, see Papasan v. 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 11211st be enough to raise a right to relief 
above the speculative level, see 51. Wright & A. Miller, Federal Practice and 
Procedure 4 1216, pp. 235-236 (3d 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 
EFTA00175321

Case 9:08-cv-80811-KAM 
Document 35 
Entered on FLSD Docket 01/07/2009 
Page 4 of 7 
. v. Epstein, et al. 
age 4 
doubtful in fact), see, e.g., Swierkiewicz v. Sorema N. A., 534 U.S. 506. 508, 
n. 1, 122 S.Ct. 992. 152 L.Ed.2d 1 (2002); Neitzke v. Williams. 490 U.S. 319, 
327, 109 S.Ct. 1827. 104 L.Ed.2d 338 (1989) (" Rule 12(b)(6) does not 
countenance ... dismissals based on a judge's disbelief of a complaint's 
factual allegations"); Scheuer v. Rhodes, 416 U.S. 232, 236. 94 S.Ct. 1683, 
40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it 
appears "that a recovery is very remote and unlikely"). 
In discussing Twombly, the Eleventh Circuit in Watts v. Fla. International Univ., 
495 F.3d 1289, 1295 (111h Cir. 2007), noted - "The Supreme Court's most recent 
formulation of the pleading specificity standard is that 'stating such a claim requires a 
complaint with enough factual matter (taken as true) to suggest' the required element." 
In order to sufficiently allege the claim, the complaint is required to identify "facts that 
are suggestive enough to render [the element] plausible." Watts 495 F.3d at 1296 
(quoting Twombly, 127 S.Ct. at 1965). 
As jurisdiction is based on diversity, it is well settled that this Court is to apply 
Florida substantive law in this action. Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938). 
On its face, Count I completely fails to allege either the necessary elements of 
any cause of action or the necessary underlying factual allegations. As quoted above, 
Count I makes general references to "lewd and lascivious conduct and/or sexual 
performances" without any specific statutory or common law reference. 
Florida Statutes, Chapter 800, Title XLVI — CRIMES, entitled "Lewdness, 
Indecent Exposure," are criminal statutes'. Assuming for the sake of argument that 
Plaintiff means to rely on these statutes, none of the statutes contained in Chapter 800 
create a private right of action. See H800.02, 800.03, 800.04, Fla. Stat. Rather, the 
' This action began in Florida state court, Palm Beach County 15th Judicial Circuit Court, and 
was removed to Federal Court pursuant to a Notice of Removal filed by Defendants. 
EFTA00175322

Case 9:08-cv-80811-KAM 
Document 35 
Entered on FLSD Docket 01/07/2009 
Page 5 of 7 
. v. Epstein, et al. 
Page 5 
statutes set forth acts subject to criminal prosecution and the criminal penalties therefor, 
if proven. See generally, Am. Home Assurance Co. v. Plaza Materials Corp., 908 So.2d 
360, 374 (Fla. 2005)("not every statutory violation carries a civil remedy'); and Miami 
Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 1985)(violation of Florida's 
criminal extortion statute does not give rise to civil cause of action for damages). 
According, Count I is required to be dismissed as Chapter 800, which references lewd 
conduct, does not create a private right of action. Mantooth v. Richards, 557 So.2d 646 
(Fla. 4th DCA 1990), per curiam, (Dismissal of plaintiffs civil complaint affirmed where 
parental kidnapping statutes concerned only criminal violations and did not create a civil 
remedy). 
As well, the Count I allegations make absolutely no reference to any viable 
common law cause of action; Defendant should not be required to guess or speculate 
as to the nature of Plaintiffs cause of action. Even if Defendant were to speculate as to 
the supposed cause of action, these causes of action (common law or otherwise) have 
not been sufficiently alleged. On its face, Count I is completely lacking as to any 
common law elements or the underlying factual allegations to support each element, 
and thus, Count I is required to be dismissed. 
Finally, as noted, there are no allegations as to time regarding the alleged 
"numerous occasions." Pursuant to Rule 9(f), Fed.R.Civ.P., "pleadings of time or place 
is material when testing the sufficiency of a pleading." 
Conclusion 
EFTA00175323

Case 9:08-cv-80811-KAM 
Document 35 
Entered on FLSD Docket 01/07/2009 
Page 6 of 7 
116 
v. Epstein, et al. 
Pursuant to applicable law, Count I of Plaintiff's Complaint is required to be 
dismissed for failure to state a cause of action. On its face, Count I fails to allege a 
cause of action either under statutory or common law against Defendant EPSTEIN. 
Count I fails to plead any requisite elements or the necessary underlying facts. 
WHEREFORE, Defendant requests that Count I of Plaintiffs Complaint be 
dismissed for failure to state a cause of action. 
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 7th day of  January, 2009: 
Richard Horace Willits, Esq. 
Richard H. Willits, P.A. 
2290 10th Avenue North 
Suite 404 
L m k Worth FL 33461 
imo
 s
Fax: 
C unse or ainti 
Jack Scarola, Esq. 
Jack P. Hill, Esq. 
Search 
Denney 
Scarola 
Barnhart 
Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
st Palm Beach, FL 33409 
Fax: 
jsxesearcvlaw.com 
jphesearcylaw.com 
Co-Counsel for Plaintiff 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, FL 33401-5012 
net 
Counsel for Defendants Jeffrey Epstein 
and 
Bruce Reinhart, Esq. 
& Bruce E. Reinhart, P.A. 
250 S. Australian Avenue 
Suite 1400 
West Palm beach, FL 33401 
ounse or e en an 
Respectfully submitted, 
EFTA00175324

Case 9:08-cv-80811-KAM 
Document 35 
Entered on FLSD Docket 01/07/2009 
Page 7 of 7 
v. Epstein, et al. 
By: 
ROBERT D. RITTON, JR., ESQ. 
Florida Bar o. 224162 
rcrit©bcIcl w.com 
MICHAEL J. PIKE, ESQ. 
Florida Bar #617296 
moikeebdclaw.com 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 N. Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
Phone 
Fax 
ounce or .efendant Jeffrey Epstein) 
EFTA00175325

CM/ECF - !Ave Database - flsd 
Page 1 of 16 
LSS, MEDIATION, REF_DISCOV 
U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE #: 9:08-cv-80811-KAM 
MI 
v. Epstein et al 
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: 28:1332 Diversity 
Plaintiff
V. 
Defendant 
Jeffrey Epstein 
Date Filed: 07/21/2008 
Jury Demand: Plaintiff 
Nature of Suit: 360 P.I.: Other 
Jurisdiction: Diversity 
represented by Richard Horace Willits 
Richard H Willits PA 
2290 10th Avenue North 
Suite 404 
Lake Worth , FL 33461 
Fax: 
Emai : ree r 
otmail.com 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Jack Patrick Hill 
Searcy Denney Scarola Barnhart & 
Shipley 
2139 Palm Beach Lakes Boulevard 
PO Drawer 3626 
West Palm Beach , FL 33402-3626 
PIM 
Email:
represented by Bruce Reinhart 
Bruce E. Reinhart, P.A. 
https://ecf.flsd.uscourts.gov/ogi-bin/D1ctRpt.p17985369616841682-1.,801_0-1 
6/10/2009 
EFTA00175326

CM/ECF - !Ave Database - flsd 
Page 2 of 16 
250 S. Australian Avenue 
Suite 1400 
West Palm Beach , FL 33401 
Fax: 
Emai 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Guy Alan Lewis 
Lewis Tein 
3059 Grand Avenue 
Suite 340 
Coconut Grove , FL 33133 
Fax: 442-6744 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Jack Alan Goldberger 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach , FL 33401-5012 
Fax: 835-8691 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Michael Ross Tein 
Lewis Tein 
3059 Grand Avenue 
Suite 340 
Coconut Grove , FL 33133 
Fax: 442-6744 
Email: tein@lewistein.com 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Michael James Pike 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
https://ecf.flsd.useourts.gov/cgi-bin/DktRpt.pl?985369616841682-L_801_0-1 
6/10/2009 
EFTA00175327

CM/ECF - Live Database - flsd 
Page 3 of 16 
Suite 400 
West Palm Beach , FL 33401-2918 
Fax: 515-3148 
Email: MPike@bciclaw.com 
ATTORNEY TO BE NOTICED 
Robert Deweese Critton , Jr. 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Defendant 
represented by Bruce Reinhart 
(See above for address) 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Guy Alan Lewis 
(See above for address) 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Jack Alan Goldberger 
(See above for address) 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Michael Ross Tein 
(See above for address) 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Amiens 
United States of America 
represented by 
United States Attorney's Office 
500 East Broward Blvd 
7th Floor 
Ft Lauderdale , FL 33394 
, ext. 3546 
https://ecf.flsd.uscourts.gov/egi-bin/DktRpt.pl?985369616841682-L_801_0-1 
6/10/2009 
EFTA00175328

CM/ECF - Live Database - flsd 
Page 4 of 16 
Fax: 356-7336 
Email: 
ATTORNEY TO BE NOTICED 
Date Filed 
# 
clear Docket Text 
07/21/2008 
1 
r 
MB 
IA
NOTICE OF REMOVAL Filing fee $350 Receipt#: 724505, filed by 
Jeffrey Epstein, MI 
(rb) (Entered: 07/21/2008) 
07/22/2008 
2 
r 
972
ica 
ORDER of Instructions. Signed by Judge William J. Zloch on 7/22/2008. 
(bc) (Entered: 07/22/2008) 
07/25/2008 
3 
IT 
I " xs 
MOTION for Hal 
Defendants' Request for Oral Argument by Jeffrey 
Epstein, 
(Tein, Michael) (Entered: 07/25/2008) 
07/25/2008 
4 
r 
57.9 
KB
MOTION for Extension of Time to File Answer Defendants Motion for 
Enlargement of Time to Answer or Otherwise Respond to Complaint by 
Jeffrey Epstein, 
(Tein, Michael) (Entered: 07/25/2008) 
07/25/2008 
5 r 
521
Ica 
NOTICE by Jeffrey Epstein!". 
Notice of Related Actions 
(Tein, Michael) (Entered: 07 
07/25/2008 
6 
Sealed Document. (igo) UNSEALED see DE 32 Modified on 1/7/2009 
(ral). (Entered: 07/25/2008) 
07/25/2008 
7 
Sealed Document. (igo) UNSEALED see DE 33 Modified on 1/7/2009 
(ral). (Entered: 07/25/2008) 
07/25/2008 
32 
r
93.1 
KB
UNSEALED MOTION to File Under Seal by Jeffrey Epstein, 
(previously filed as 6 sealed document) (ral) (Entered: 
01/07/2009) 
07/25/2008 
la r 
1.6 
MB 
UNSEALED MOTION to Stay by Jeffrey Epstein, IMINE. 
(previously filed as 7 sealed document)(ral) (EntereETT/777709) 
07/29/2008 
8 r
92.1 
KB 
ORDER denying without prejudice 4 Motion for Extension of Time to 
Respond to Complaint. Signed by Judge William J. Zloch on 7/28/2008. 
(bc) (Entered: 07/29/2008) 
07/30/2008 
2 
ri 
94.6 
KB
MOTION for Extension of Time to File Answer Defendants' Renewed 
Motion for Enlargement of Time to Answer or Otherwise Respond to 
Complaint by Jeffrey Epstein, 
. (Attachments: # 1 Text of 
Proposed Order Proposed Order 
ein, 
wheel) (Entered: 07/30/2008) 
07/30/2008 
10 
PAPERLESS ORDER denying 3 Motion for Hearing. Signed by Judge 
https://ecfflsd.uscourts.gov/cgi bin/DktRptpl?985369616841682-L_801_0-1 
6/10/2009 
EFTA00175329

CM/ECF - Live Database - flsd 
Page 5 of 16 
William J. Zloch on 7/30/2008. (bc) (Entered: 07/30/2008) 
08/06/2008 
11 
PAPERLESS ORDER granting 9 Motion for Extension of Time to 
Respond to Complaint. Signed by Judge William J. Zloch on 8/6/2008. 
(bc) (Entered: 08/06/2008) 
08/07/2008 
12 
I 
173
KB 
MOTION to Reassign Case TO JUDGE KENNETH MARRA by 
. 
(Willits, Richard) (Entered: 08/07/2008) 
08/07/2008 
B 
r 
34.1 
KB 
MEMORANDUM in Opposition re 6 Sealed Document, 7 Sealed 
Document TO MOTION TO STAY filed by 
.. (Willits, Richard) 
(Entered: 08/07/2008) 
08/14/2008 
14 
PAPERLESS ORDER denying 12 Motion to Reassign Case. Signed by 
Judge William J. Zloch on 8/14/2008. (bc) (Entered: 08/14/2008) 
08/18/2008 
15 
r 
9g 
MOTION for Extension of Time to File Reply Defendants' Motion for An 
Enlargement of Time to File RalthInder Seal Because of Tropical Storm 
Fay by Jeffrey Epstein, 
IME. (Attachments: # 1 Text of Proposed 
Order)(Tein, Michael) (Entered: 08/18/2008) 
08/18/2008 
16 
r 
40.2 
Ica 
SCHEDULING REPORT- Rule 26(f). (Tein, Michael) (Entered: 
08/18/2008) 
08/20/2008 
17 
Sealed Document. (rb) UNSEALED see DE 34 Modified on 1/7/2009 
(ml). (Entered: 08/20/2008) 
08/20/2008 
34 
r 
o.s 
MB 
UNSEALED REPLY in Support of 33 MOTION to Stay filed by Jeffrey 
Epstein, 
(previously filed as 17 sealed document) (ra 1) 
(Entered: 01/07/2009) 
08/25/2008 
18 
PAPERLESS ORDER granting 15 Motion for Extension of Time to 
Respond. Signed by Judge William J. Zloch on 8/25/2008. (bc) (Entered: 
08/25/2008) 
08/27/2008 
19 
r 
143.3 
KB 
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 19 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 
20 
NOTICE of Attorney Appearance by Michael James Pike, Robert 
Deweese Critton, Jr on behalf of Jeffrey Epstein. Redocketed SEE Image 
19 (ail) (Entered: 08/28/2008) 
09/03/2008 
21 
r 
ORDER REASSIGNING CASE. Case reassigned to Judge Kenneth A. 
Marra for all further proceedings. Judge William J. Zloch no longer 
https://ecf.flsd.uscourts.gov/egi-bin/D1ctRpt.p11/985369616841682-L_801_0-1 
6/10/2009 
EFTA00175330

CM/ECF - Live Database - flsd 
Page 6 of 16 
• 
501
KB 
assigned to case. Signed by Judge William J. Zloch on 8/29/2008. (tb) 
(Entered: 09/03/2008) 
09/06/2008 
22 r 
163
Ica 
MOTION to Preserve Evidence by 
.. (Willits, Richard) (Entered: 
09/06/2008) 
09/06/2008 
23 
MOTION to Expedite certain discovery by 
.. (see image 2/ ) (tb) 
(Entered: 09/09/2008) 
09/09/2008 
Clerks Notice of Docket Correction and Instruction to Filer re 22 
MOTION to Preserve Evidence filed by 
.. Error - Motion with 
Multiple Reliefs Filed as One Relief; Correction - Additional relief(s) 
23 
docketed by Clerk. Instructions to filer - In the future, please 
select all applicable reliefs. It is not necessary to refile this document. (tb) 
(Entered: 09/09/2008) 
09/15/2008 
24 r
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ORDER denying in part n Motion to Preserve Evidence; granting in part 
23 Motion to Expedite. Signed by Judge Kenneth A. Marra on 9/14/08. 
(ir) (Entered: 09/15/2008) 
12/01/2008 
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NOTICE of Attorney Appearance by Jack Patrick Hill on behalf of 
(Hill, Jack) (Entered: 12/01/2008) 
12/10/2008 
26 
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ORDER SETTING TRIAL DATE & Discovery Deadlines; ORDER 
REFERRING CASE to Mediation, ORDER REFERRING CASE to 
Magistrate Judge Linnea R. Johnson for Discovery Proceedings: (Jury 
Trial set for 12/14/2009 in West Palm Beach Division before Judge 
Kenneth A. Marra., Calendar Call set for 12/11/2009 10:00 AM in West 
Palm Beach Division before Judge Kenneth A. Marra., Amended 
Pleadings/Add Parties due by 12/1/2008., Discovery due by 5/28/2009., 
Substantive Pretrial Motions due by 7/30/2009.),. **Please see Order for 
further details" Signed by Judge Kenneth A. Marra on 12/10/2008. (gp) 
(Entered: 12/11/2008) 
12/17/2008 
27 r
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ORDER DENYING MOTION TO SEAL re 6 Sealed Document, 17 
Sealed Document, 7 Sealed Document. The clerk shall unseal docket 
entries 6, 7 and 17 and make them available for public inspection through 
CM/ECF at the earliest possible time. Signed by Judge Kenneth A. Marra 
on 12/16/2008. (ir) (Entered: 12/17/2008) 
12/17/2008 
28 
,r7n
`K; 
ORDER DENYING MOTION TO STAY 6 Sealed Document, 7 Sealed 
Document. Per this Court's Order DE 27 the Clerk shall unseal and 
terminate these pending documents. Signed by Judge Kenneth A. Marra 
on 12/16/2008. (ir) (Entered: 12/17/2008) 
12/19/2008 
29 
F 
360.1 
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Defendant's MOTION for Extension of Time to File Response to 
Complaint by Jeffrey Epstein. (Critton, Robert) (Entered: 12/19/2008) 
httos://ecfflsd.uscourts.gov/cgi bin/DktRptp17)85369616841682-L_801_0-1 
6/10/2009 
EFTA00175331

CM/ECF -Live Database - flsd 
Page 7 of 16 
12/19/2408 
30 
ENDORSED ORDER granting 29 Motion for Extension of Time to 
Answer Complaint. Jeffrey Epstein response due 1/7/2009. Signed by 
Judge Kenneth A. Marra on 12/19/2008. (ir) (Entered: 12/19/2008) 
12/30/2008 
31 
I - 
7" 
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NOTICE by Jeffrey Epstein of Withdrawal as Co-Counsel (Tein, Michael) 
(Entered: 12/30/2008) 
01/07/2009 
35 
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Defendant's MOTION to Dismiss 1 Notice of Removal Complaint for 
Failure to State a Cause of Action by Jeffrey Epstein. Responses due by 
1/26/2009 (Critton, Robert) (Entered: 01/07/2009) 
01/22/2009 
36 
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MOTION for Extension of Time to File Response as to 35 Defendant's 
MOTION to Dismiss.1 M...a lice of Removal Complaint for Failure to State 
a Cause of Action by.a.. 
(Hill, Jack) (Entered: 01/22/2009) 
01/23/2009 
37 
ENDORSED ORDER granting 16 Motion for Extension of Time to 
Respond re a5. Defendant's MOTION to Dismiss 1 Notice of Removal 
Complaint for Failure to State a Cause of Action. Amended Complaint 
due by 2/9/2009. Signed by Judge Kenneth A. Marra on 1/22/2009. (ir) 
(Entered: 01/23/2009) 
02/05/2009 
38 
1 4: 
MOTION for Entry of an Amended Scheduling Order re 26 Scheduling 
Order,,, Order Referriarage to Mediation,,, Order Referring Case to 
Magistrate Judge„ by
.. (Attachments: # 1 Exhibit Proposed 
Amended Order Setting Trial Date)(Hill, Jack) (Entered: 02/05/2009) 
02/09/2009 
39 
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AMENDED COMPLAINT, filed byall..(Hill, Jack) (Entered: 
02/09/2009) 
02/09/2009 
40 
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AMENDED COMPLAINT, filed by 
..(Hill, Jack) (Entered: 
 02/09/2009) 
02/10/2009 
41 
IT 
55.6
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ORDER denying as moot 35 Motion to Dismiss Complaint. Signed by 
Judge Kenneth A. Marra on 2/10/2009. (ir) (Entered: 02/10/2009) 
02/10/2009 
42 
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INagaLMOTION for Extension of Time to File Selection of Mediator 
by..... 
(Hill, Jack) (Entered: 02/10/2009) 
02/10/2009 
4a 
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ORDER granting 38 Motion for entry of an Amended Scheduling Order. 
Signed by Judge Kenneth A. Man-a on 2/10/2009. (ir) (Entered: 
02/10/2009) 
02/10/2009 
Reset Scheduling Order Deadlines: Calendar Call set for 2/19/2010 10:00 
AM in West Palm Beach Division before Judge Kenneth A. Marra. Jury 
Trial set for 2/22/2010 09:00 AM in West Palm Beach Division before 
Judge Kenneth A. Marra. Amended Pleadings due by 3/16/2009. 
Discovery due by 8/28/2009. Expert Discovery due by 6/29/2009. Joinder 
of Parties due by 3/16/2009. Dispositive Motions due by 10/15/2009. (ir) 
https://ectflsd.uscourts.gov/cgi bin/DktRpt.pl?985369616841682-L 8010-1 
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CM/ECF -Live Database - flsd 
Page 8 of 16 
(Entered: 02/10/2009) 
02/11/2009 
44 
ENDORSED ORDER denying as moot 42 Motion for Extension of 
Deadline for parties to select mediator. Amended scheduling order entered 
on 2/10/09. Signed by Judge Kenneth A. Marra on 2/11/2009. (ir) 
(Entered: 02/11/2009) 
02/17/2009 
45 
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Defendant's MOTION for Extension of Time to File Response as to 4Q 
Amended Complaint with proposed Agred Order by Jeffrey Epstein. 
(Critton, Robert) (Entered: 02/17/2009) 
02/17/2009 
46 r
31.4 
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ORDER granting 45 Motion for Extension of Time to Answer First 
Amended Complaint. Jeffrey Epstein response due 3/12/2009. Signed by 
Judge Kenneth A. Marra on 2/17/2009. (ir) (Entered: 02/17/2009) 
03/12/2009 
47 
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Defendant's MOTION to Dismiss 4() Amended Complaint (First) by 
Jeffrey Epstein. Responses due by 3/30/2009 (Pike, Michael) (Entered: 
03/12/2009) 
03/12/2009 
4$ 
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53.9 
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NOTICE of Cancelling Deposition (ail) (Entered: 03/13/2009) 
03/16/2009 
49 
n 
483.1 
KB 
Defendant's MOTION for Extension of Time to File Motion to Compel 
Answers to Interrogs and Production of Documents w/ Proposed Order by 
Jeffrey Epstein. (Critton, Robert) (Entered: 03/16/2009) 
03/19/2009 
50 
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ORDER Granting 49 Motion for Extension of Time to File Motions to 
Compel Answers to Interrogatories and Production of Documents directed 
to Plaintiff. Defendant shall file Motions on or before 4/6/09. Signed by 
Magistrate Judge Linnea R. Johnson on 3/19/2009. (sa) (Entered: 
03/19/2009) 
03/24/2009 
51 
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29
Defendant's MOTION to Stay re 4() Amended Complaint and or Continue 
Action by Jeffrey Epstein. Responses due by 4/10/2009 (Attachments: # 1 
Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Pike, Michael) (Entered: 
03/24/2009) 
03/25/2009 
52 
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Plaintiffs MOTION for Extension of Time to File Response as to 41 
Defendant's MOTION to Dismiss 40 Amended Complaint (First) by 
.. (Hill, Jack) (Entered: 03/25/2009) 
03/26/2009 
53 
ENDORSED ORDER granting 52 Motion for Extension of Time to 
Respond re 47 Defendant's MOTION to Dismiss 4() Amended Complaint 
(First). Responses due by 4/13/2009. Signed by Judge Kenneth A. Marra 
on 3/26/2009. (ir) (Entered: 03/26/2009) 
04/02/2009 
54 
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Defendant's MOTION to Compel Response to 1st RTP and 1st Interrogs 
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: 
https://ecf.flsd.uscourts.gov/egi-bitt/DktRpt.p17985369616841682-L_801_0-1 
6/10/2009 
EFTA00175333