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LRJ 
U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE #: 9:08-cv-80232-KAM 
Doe No. 3 v. Epstein 
Assigned to: Judge Kenneth A. Marra 
Lead case: 2:flasaAhd 
Member case: (View Member Case) 
Case: 9:09-cv-80802-KAM 
Cause: 28:1332 Diversity-Personal Injury 
Plaintiff 
Jane Doe No. 3 
Date Filed: 03/05/2008 
Jury Demand: Plaintiff 
Nature of Suit: 360 P.I.: Other 
Jurisdiction: Diversity 
represented by Adam D. Horowitz 
Mermelstein & Horowitz PA 
18205 Biscayne Boulevard 
Suite 2218 
Miami FL 33160 
Fax: 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Jeffrey Marc Herman 
I lennan & 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 
Miami FL 33160 
Fax: 931-0877 
Email: 
LEAD ATTORNEY 
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ATTORNEY TO BE NOTICED 
Defendant
Jeffrey Epstein 
Amicua
United States of America 
represented by Michael James Pike 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Fax: 515-3148 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Robert Deweese Critton , Jr. 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
s P Im Beach , FL 33401-2918 
Fax: 
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 
Email: 
ATTORNEY TO BE NOTICED 
Michael Ross Tein 
Lewis Tein 
3059 Grand Avenue 
Suite 340 
ve , FL,33133 
represented by II 
C. 
Unite States Attorney's Office 
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500 East Broward Blvd 
7th Floor 
Ft Lauderdale , FL 33394 
ext. 3546 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Date Filed 
# 
Docket Text 
03/05/2008 
1 COMPLAINT against Jeffrey Epstein. Filing fee $350. Receipt No. 542467, 
filed by Jane Doe No. 3.(caw) (Entered: 03/05/2008) 
03/05/2008 
2 Summons Issued as to Jeffrey Epstein. (caw) (Entered: 03/05/2008) 
03/11/2008 
3 ORDER requiring counsel to confer, file joint scheduling report and file joint 
discovery report;Signed by Judge Kenneth A. Marra on 03/11/2008.(bs) 
(Entered: 03/11/2008) 
05/22/2008 
4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey 
Epstein on May 7, 2008, filed by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 
05/22/2008) 
05/29/2008 
5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane 
Doe No. 3. (Attachments: # 1 Exhibit A and B, # 2 Text of Proposed Order 
Default Order)(Horowitz, Adam) (Entered: 05/29/2008) 
06/13/2008 
6 NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of 
Jeffrey Epstein (Goldberger, Jack) (Entered: 06/13/2008) 
06/13/2008 
7 RESPONSE to Motion re 5 Plaintiffs MOTION for Entry of Default by Clerk 
Against Defendant Jane Doe No. 3 filed by Jeffrey Epstein. Replies due by 
6/23/2008. (Attachments: # I Affidavit of Richard Bamett)(Goldberger, Jack) 
(Entered: 06/13/2008) 
06/20/2008 
a Defendant's MOTION to Stay by Jeffrey Epstein. Responses due by 7/10/2008 
(Goldberger, Jack) (Entered: 06/20/2008) 
06/20/2008 
9 Defendant's MOTION for Extension of Time to File Answer Or Otherwise 
Respond To Complaint by Jeffrey Epstein. (Goldberger, Jack) (Entered: 
06/20/2008) 
06/24/2008 
IQ MEMORANDUM in Support re 5 Plaintiffs MOTION for Entry of Default 
by Clerk Against Defendant filed by Jane Doe No. 3. (Herman, Jeffrey) 
(Entered: 06/24/2008) 
07/01/2008 
11 NOTICE by Jeffrey Epstein Concerning Motion To Stay [DE 8.1 
(Attachments: # 1 Exhibit "A" Final Disposition SheetsXGoldberger, Jack) 
(Entered: 07/01/2008) 
07/08/2008 
12 NOTICE of Attorney Appearance by Michael Ross Tein on behalf of Jeffrey 
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Epstein (rein, Michael) (Entered: 07/08/2008) 
07/10/2008 
13 Plaintiffs MOTION for Extension of Time to File Response as to a 
Defendant's MOTION to Stay by Jane Doe No. 3. (Attachments: # I Text of 
Proposed OrderXHorowitz, Adam) (Entered: 07/10/2008) 
07/10/2008 
14 Sealed Document. (yc) UNSEALED see DE .111. Modified on 7/17/2008 (bs). 
(Entered: 07/10/2008) 
07/10/2008 
15 Sealed Document. (yc) UNSEALED see DE 19 . Modified on 7/17/2008 (bs). 
(Entered: 07/10/2008) 
07/10/2008 
18 UNSEALED MOTION to Seal by Jeffrey Epstein. (previously filed as 14 
sealed document) (bs) (Entered: 07/17/2008) 
07/10/2008 
19 UNSEALED Notice of Continued Pendency of Federal Criminal Action by 
Jeffrey Epstein (previously filed as 15 sealed document) (bs) (Entered: 
07/17/2008) 
07/16/2008 
A ORDER denying motion to file Ex Parte and Under Seal. The clerk shall 
unseal DE 14 and 15 and make them available for public inspection through 
CM/ECF at the earliest possible time. Signed by Judge Kenneth A. Marra on 
7/16/08. (ir) (Additional attachments) added on 7/17/2008: # 1 docket sheet) 
(bs). (Entered: 07/16/2008) 
07/16/2008 
17 ORDER TO SHOW CAUSE why default should not be entered against 
Defendant. Show Cause Response due by 7/28/2008. Signed by Judge 
Kenneth A. Marra on 7/16/08. (ir) (Entered: 07/16/2008) 
07/18/2008 
20 RESPONSE to Motion re a Defendant's MOTION to Stay and Memorandum 
of Law filed by Jane Doe No. 3. Replies due by 7/28/2008. (Attachments: # 1 
Exhibit A)(Herman, Jeffrey) (Entered: 07/18/2008) 
07/21/2008 
21 AFFIDAVIT signed by : Jeffrey M. Herman. re U Order to Show Cause and 
Service of Process by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 
07/21/2008) 
07/25/2008 
22 MOTION for Hearing Defendant's Request for Oral Argument by Jeffrey 
Epstein. (Tein, Michael) (Entered: 07/25/2008) 
07/25/2008 
21 ORDER denying I Motion for Entry of Default. The defendant is relieved of 
responsibility from responding to the Court's Order to Show Cause issued on 
7/16/08 DE17 . Signed by Judge Kenneth A. Marra on 7/25/08. (ir) (Entered: 
07/25/2008) 
07/28/2008 
24 UNSEALED Sealed Document. (tas) Modified on 8/12/2008 (gp) **For 
Image please see DE # 32 " . (Entered: 07/28/2008) 
07/28/2008 
25 UNSEALED Sealed Document. (tas) -Modified on 8/12/2008 (gp) **For 
Image please see DE # 33 ** . (Entered: 07/28/2008) 
07/28/2008 
32 MOTION to File Under Seal by Jeffrey Epstein. {Originally DE # 24 } (gp) 
(Entered: 08/12/2008) 
07/28/2008 
33 REPLY to Response to Motion re a Defendant's MOTION to Stay filed by 
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Jeffrey Epstein. {Originally DE # 25 } (gp) (Entered: 08/12/2008) 
07/29/2008 
26 NOTICE by Jeffrey Epstein Defendant's Notice of Filing Exhibits 
(Attachments: # 1 Exhibit A, # 2 Exhibit B)(Tein, Michael) (Entered: 
07/29/2008) 
07/30/2008 
22 NOTICE by Jeffrey Epstein Waiver of Service (Tein, Michael) (Entered: 
07/30/2008) 
08/05/2008 
28 ORDER DENYING MOTION TO SEAL.The Clerk shall unseal DE 24 
Sealed Document, 25 Sealed Document and make them available for public 
inspection through CM/ECF. Signed by Judge Kenneth A. Marra on 8/4/08. 
(ir) (Entered: 08/05/2008) 
08/05/2008 
22 ORDER denying a Motion to Stay; granting nunc pro tune la Motion for 
Extension of Time to Respond ; denying as moot 22 Motion for Hearing. 
Signed by Judge Kenneth A. Marra on 8/4/08. (ir) (Entered: 08/05/2008) 
08/06/2008 
3.0 Joint MOTION to Approve Stipulation for Acceptance of Service of Process 
and Agreed Date for Defendant's Responses to Complaints by Jane Doe No. 3. 
(Attachments: # 1 Stipulation, # 2 Text of Proposed Order Granting 
Stipulation)(Herman, Jeffrey) (Entered: 08/06/2008) 
08/07/2008 
31 ENDORSED ORDER granting aQ Motion to approve stipulation for 
acceptance of service of process and agreed date for defendant's responses to 
complaints. Signed by Judge Kenneth A. Marra on 8/6/08. (ir) (Entered: 
08/07/2008) 
08/07/2008 
Reset Answer Due Deadline: Jeffrey Epstein response due 9/4/2008. (ir) 
(Entered: 08/07/2008) 
08/27/2008 
34 NOTICE by Jeffrey Epstein Notice of Appearance (Pike, Michael) (Entered: 
08/27/2008) 
08/29/2008 
Clerks Notice of Instruction to Filer re 3A Notice (Other) filed by Jeffrey 
Epstein. Error - Wrong Event Selected; Instruction to Filer - In the future, 
please select the proper event, notice of attorney appearance located under 
notices. It is not necessary to refile this document. (tb) (Entered: 08/29/2008) 
09/04/2008 
35 Defendant's MOTION to Dismiss 1 Complaint by Jeffrey Epstein. Responses 
due by 9/22/2008 (rein, Michael) (Entered: 09/04/2008) 
09/22/2008 
36 MEMORANDUM in Opposition re 35 Defendant's MOTION to Dismiss 1 
Complaint filed by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 09/22/2008) 
09/22/2008 
37 AMENDED COMPLAINT, filed by Jane Doe No. 3.(Herman, Jeffrey) 
(Entered: 09/22/2008) 
09/23/2008 
a 
ORDER denying as moot 31 Motion to Dismiss; denying as moot 9 Motion 
for Extension of Time to Respond to Complaint. Signed by Judge Kenneth A. 
Marra on 9/23/08. (ir) (Entered: 09/23/2008) 
09/25/2008 
39 SCHEDULING REPORT- Rule 26(O. (Herman, Jeffrey) (Entered: 
09/25/2008) 
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09/30/2008 
4.Q SCHEDULING ORDER: Jury Trial set for 1/25/2010 09:00 AM in West 
Palm Beach Division before Judge Kenneth A. Marra. Calendar Call set for 
1/22/2010 10:00 AM in West Palm Beach Division before Judge Kenneth A. 
Marra., Amended Pleadings due by 12/1/2008. Discovery due by 8/3/2009. 
Motions due by 8/31/2009. ORDER REFERRING CASE to Magistrate Judge 
Linnea R. Johnson for Discovery Proceedings, ORDER REFERRING CASE 
to Mediation. 15 days to appoint mediator. Signed by Judge Kenneth A. Marra 
on 9/29/08. (ir) (Entered: 09/30/2008) 
10/06/2008 
41 Defendant's MOTION to Dismiss 3.7 Amended Complaint and for More 
Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Critton, 
Robert) (Entered: 10/06/2008) 
10 `06%2008 
42 MOTION for More Definite Statement directed to amended complaint by 
Jeffrey Epstein. See image DE 41(1k) (Entered: 10/07/2008) 
I 0 07 2008 
Clerks Notice of Docket Correction and Instruction to Filer re 41 Defendant's 
MOTION to Dismiss 32 Amended Complaint and for More Definite 
Statement filed by Jeffrey Epstein. Error - Motion with Multiple Reliefs 
Filed as One Relief; Correction - Additional relief(s) 42 docketed by Clerk. 
Instructions to filer - In the future, please select all applicable reliefs. It is not 
necessary to refile this document. (1k) (Entered: 10/07/2008) 
10.24 2008 
41 Unopposed MOTION for Extension of Time to File Response as to 41 
Defendant's MOTION to Dismiss 32 Amended Complaint and for More 
Definite Statement by Jane Doe No. 3. (Attachments: # .1_ Text of Proposed 
Order)(Herman, Jeffrey) (Entered: 10/24/2008) 
10 2 7 2008 
44 ORDER granting (47 in 9:08-cv-80119-KAM) Unopposed MOTION for 
Extension of Time to File Response as to (46) Defendant's MOTION to 
Dismiss (42) Amended Complaint and for More Definite Statement 
( Responses due by 10/31/2008) in case 9:08-cv-80119-KAM; granting (43) 
Motion for Extension of Time to Respond re (47 in 9:08-ov-80119-KAM) 
Unopposed MOTION for Extension of Time to File Response as to (46) 
Defendant's MOTION to Dismiss (42) Amended Complaint and for More 
Definite Statement in case 9:08-cv-80232-KAM; granting (55) Motion for 
Extension of Time to Respond re (47 in 9:08-cv-80119-1CAM) Unopposed 
MOTION for Extension of Time to File Response as to (46) Defendant's 
MOTION to Dismiss (42) Amended Complaint and for More Definite 
Statement in case 9:08-cv-80380-KAM; granting (53) Motion for Extension of 
Time to Respond re (47 in 9:08-cv-80119-ICAM) Unopposed MOTION for 
Extension of Time to File Response as to (46) Defendant's MOTION to 
Dismiss (42) Amended Complaint and for More Definite Statement in case 
9:08-cv-80381-KAM in case 9:08-cv-80119-KAM. Signed by Judge Kenneth 
A. Marra on 10/24/2008. (ir) (Entered: 10/27/2008) 
10/28/2008 
Reset Deadlines as to Defendant's MOTION to Dismiss (49) Amended 
Complaint and for More Definite Statement. Responses due by 10/31/2008. 
(ir) (Entered: 10/28/2008) 
10/31/2008 
45 MEMORANDUM in Opposition re 41 Defendant's MOTION to Dismiss 37 
Amended Complaint and for More Definite Statement filed by Jane Doe No. 
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3. (Attachments: # 1 Exhibit A)(Herman, Jeffrey) (Entered: 10/31/2008) 
11/10/2008 
46 RESPONSE/REPLY to 4. Memorandum in Opposition to Defendant's Motion 
to Dismiss filed by Jeffrey Epstein. (Critton, Robert) (Entered: 11/10/2008) 
12/30/2008 
42 NOTICE by Jeffrey Epstein of Withdrawal as Co-Counsel (Tein, Michael) 
(Entered: 12/30/2008) 
02/12/2009 
41 ORDER AND OPINION granting in part and denying in part 41 Motion to 
Dismiss; denying 42 Motion for More Definite Statement. Signed by Judge 
Kenneth A. Marra on 2/12/2009. (ir) Modified on 2/12/2009 to reflect correct 
signature date (bb). (Entered: 02/12/2009) 
02/23/2009 
42 NOTICE by Jane Doe No. 3 of Change of Name ofPlaints Counsel 
(Horowitz, Adam) (Entered: 02/23/2009) 
02/27/2009 
50 AMENDED COMPLAINT (Second), filed by Jane Doe No. 3.(Horowitz, 
Adam) (Entered: 02/27/2009) 
03/02/2w) 
51 Plaintiffs MOTION to Compel Answers to Interrogatories and Production of 
Documents and Incorporated Memorandum of Law In Support by Jane Doe 
No. 3. Responses due by 3/19/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit 
B)(Horowitz, Adam) (Entered: 03/02/2009) 
03/04/2009 
52 
Defendant's MOTION for Extension of Time to File Response as to 50 
Amended Complaint with proposed Order by Jeffrey Epstein. (Critton, 
Robert) (Entered: 03/04/2009) 
03/05/2009 
53 ENDORSED ORDER granting 52 Motion for Extension of Time to Answer 
Complaint. Jeffrey Epstein response due 4/3/2009. Signed by Judge Kenneth 
A. Marra on 3/5/2009. (ir) (Entered: 03/05/2009) 
03/06/2009 
54 Defendant's MOTION for Extension of Time to File Response as to 51 
Plaintiffs MOTION to Compel Answers to Interrogatories and Production of 
Documents and Incorporated Memorandum of Law In Support with proposed 
Order by Jeffrey Epstein. (Critton, Robert) (Entered: 03/06/2009) 
03/18/2009 
55 Defendant's MOTION for Leave to File Excess Pages with proposed Order by 
Jeffrey Epstein. (Critton, Robert) (Entered: 03/18/2009) 
03/25/2009 
5_6 RESPONSE to Motion re 51 Plaintiffs MOTION to Compel Answers to 
Interrogatories and Production of Documents and Incorporated Memorandum 
of Law In Support filed by Jeffrey Epstein. Replies due by 4/6/2009. 
(Attachments: # 1 Affidavit A, # 2 Exhibit B, # a Exhibit CXCritton, Robert) 
(Entered: 03/25/2009) 
03/25/2009 
51 Defendant's MOTION to Stay re IQ Amended Complaint by Jeffrey Epstein. 
Responses due by 4/13/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 2 
Exhibit C)(Pikc, Michael) (Entered: 03/25/2009) 
03/26/2009 
58 MOTION for Protective Order Against Piecemeal Depositions of Jane doe 
No. 3, Motion to Consolidate Cases for Purposes of Discovery, and 
Incorporated Memorandum of Law in Support by Jane Doe No. 3. 
(Attachments: # 1 Exhibit A, # 2 Exhibit BXMermelstein, Stuart) (Entered: 
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03/26/2009) 
04/02/2009 
59 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, # a 
Exhibit C)(Critton, Robert) (Entered: 04/02/2009) 
04/02/2009 
61) 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, # a 
Exhibit CXCritton, Robert) (Entered: 04/02/2009) 
04/02/2009 
61 Defendant's ANSWER and Affirmative Defenses to Amended Complaint 
(Second) by Jeffrey Epstein.(Critton, Robert) (Entered: 04/02/2009) 
04/03/2009 
62 Unopposed MOTION for Extension of Time to File Reply as to 56 Response 
to Motion, to Compel Answers to Interrogatories and Production of 
Documents by Jane Doe No. 3. (Attachments: # 1 Text of Proposed Order) 
(Mermelstein, Stuart) (Entered: 04/03/2009) 
04/06/2009 
61 Defendant's MOTION for Extension of Time to File Response as to $1 
MOTION for Protective Order Against Piecemeal Depositions ofJane doe 
No. 3, 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 
64 ENDORSED ORDER granting 61 Motion for Extension of Time to Respond 
re 51 MOTION for Protective Order Against Piecemeal Depositions ofJane 
doe No. 3, 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 
65 Defendant's MOTION for Extension of Time to File Response as to 64 Order 
on Motion for Extension of Time to File Response/Reply/Answer, 51 
MOTION for Protective Order Against Piecemeal Depositions of Jane doe 
No. 3, 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) 
04/13/2009 
66 ENDORSED ORDER granting (73) Motion for Extension of Time to Respond 
re (66 in 9:08-cv-80119-1CAM) MOTION for Protective Order and to Quash 
Subpoena for Deposition ofJane 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 (65) 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-80232-KAM; granting (80) 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 ofJane Doe No. 3, Motion to 
Consolidate Cases for Purposes of Discovery, and Incorporated 
Memorandum of Law in Support in case 9:08-cv-80380-ICAM; 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 ofJane 
Doe No. 3, Motion to Consolidate Cases for Purposes of Discovery, and 
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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 
fa Unopposed MOTION for Extension of Time to File Response/Memorandum 
in Opposition to Motion to Stay and/or Continue Action by Jane Doe No. 3. 
(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 
04/13/2009) 
04/14/2009 
68 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-KAM) Defendant's 
MOTION to Stay re (56) Amended Complaint in case 9:08-cv-80232-ICAM; 
granting (82) Motion for Extension of Time to Respond re (65 in 9:08-cv-
80119-KAM) Defendant's MOTION to Stay re (56) Amended Complaint in 
case 9:08-cv-80380-KAM; granting (73) Motion for Extension of Time to 
Respond re (65 in 9:08-cv-80119-ICAM) Defendant's 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-ICAM) Defendant's 
MOTION to Stay re (56) Amended Complaint in case 9:08-cv-80993-KAM; 
granting (27) Motion for Extension of Time to Respond re (65 in 9:08-cv-
80119-1CAM) Defendant's MOTION to Stay re (56) Amended Complaint in 
case 9:08-cv-80994-KAM in case 9:08-cv-80119-ICAM. ( Responses due by 
4/23/2009). Signed by Judge Kenneth A. Marra on 4/14/2009. (ir) (Entered: 
04/14/2009) 
04/16/2009 
62 Defendant's MOTION for Extension of Time to File Response as to 5$ 
MOTION for Protective Order Against Piecemeal Depositions ofJane doe 
No. 3, Motion to Consolidate Cases for Purposes of Discovery, 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 
w RESPONSE to Motion re 58 MOTION for Protective Order Against 
Piecemeal Depositions ofJane doe No. 3, 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. (Attachments: # 1 Exhibit 
A)(Pike, Michael) (Entered: 04/17/2009) 
04/17/2009 
71 Unopposed MOTION for Extension of Time to File Response as to 52 
Defendant's MOTION to Compel Response to 1st RTP, 6Q Defendant's 
MOTION to Compel Answers to 1st 1nterrogs by Jane Doe No. 3. 
(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 
04/17/2009) 
04/20/2009 
72 ENDORSED ORDER granting 62 Motion for Extension of Time to Respond 
re 58 MOTION for Protective Order Against Piecemeal Depositions ofJane 
Doe No. 3, Motion to Consolidate Cases for Purposes of Discovery, and 
Incorporated Memorandum of Law in Support. Responses due by 4/24/2009. 
Signed by Judge Kenneth A. Marra on 4/20/2009. (ir) (Entered: 04/20/2009) 
04/20/2009 
72 MEMORANDUM in Support re 51 Plaintiffs MOTION to Compel Answers 
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to Interrogatories and Production of Documents and Incorporated 
Memorandum of Law In Support by Jane Doe No. 3. (Mermelstein, Stuart) 
(Entered: 04/20/2009) 
04/23/2009 
M RESPONSE in Opposition re 5.7 Defendant's MOTION to Stay re 5Q 
Amended Complaint filed by Jane Doe No. 3. (Mermelstein, Stuart) (Entered: 
04/23/2009) 
04/27/2009 
75 MEMORANDUM in Support re 5$ MOTION for Protective Order Against 
Piecemeal Depositions of Jane doe No. 3, Motion to Consolidate Cases for 
Purposes of Discovery, and Incorporated Memorandum of Law in Support by 
Jane Doe No. 3. (Mermelstein, Stuart) (Entered: 04/27/2009) 
04/27/2009 
76 REPLY to Response to Motion re a MOTION for Protective Order Against 
Piecemeal Depositions of Jane doe No. 3, Motion to Consolidate Cases for 
Purposes of Discovery, and Incorporated Memorandum of Law in Support 
filed by Jane Doe No. 3. See image DE 75 (1k) (Entered: 04/28/2009) 
04/28/2009 
77 Clerks Notice of Docket Correction and Instruction to Filer re 75 
Memorandum in Support, filed by Jane Doe No. 3. ERROR - Wrong Event 
Selected; Correction - Redocketed by Clerk as 76 REPLY TO RESPONSE 
TO MOTION. Instruction to Filer - In the future, please select the proper 
event. It is not necessary to refile this document. (1k) (Entered: 04/28/2009) 
04/29/2009 
7$ ORDER granting 55 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 
72 Unopposed MOTION for Extension of Time to File Response as to 52 
Defendant's MOTION to Compel Response to 1st RTP, 0 Defendant's 
MOTION to Compel Answers to 1st Interrogs by Jane Doe No. 3. 
(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 
04/29/2009) 
05/04/2009 
0 
MEMORANDUM in Opposition re 7$ Order on Motion for Protective Order 
by Jeffrey Epstein. (Pike, Michael) (Entered: 05/04/2009) 
05/05/2009 
11 Defendant's MOTION for Extension of Time to File Reply as to 7A Response 
in Opposition to Motion to Stay by Jeffrey Epstein. (Pike, Michael) (Entered: 
05/05/2009) 
05/06/2009 
82 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-ev-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-KAM) 
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 
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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-80994-ICAM in case 9:08-
cv-80119-KAM. ( Replies due by 5/20/2009.). Signed by Judge Kenneth A. 
Marra on 5/5/2009. (ir) (Entered: 05/06/2009) 
05/06/2009 
II
RESPONSE in Opposition re 60 Defendant's MOTION to Compel Answers to 
1st Interrogs and for an Award of Reasonable Expenses filed by Jane Doe No. 
3. (Horowitz, Adam) (Entered: 05/06/2009) 
05/06/2009 
$4 Defendant's MOTION to Compel or !dentin; Doe 3 in Style of Case and in 
Third Party Subpoenas by Jeffrey Epstein. Responses due by 5/26/2009 
(Attachments: # I Exhibit A)(Pike, Michael) (Entered: 05/06/2009) 
05/06/2009 
li
RESPONSE in Opposition re 59 Defendant's MOTION to Compel Response 
to 1st RTP , Overrule Objections and for an Award of Reasonable Expenses 
filed by Jane Doe No. 3. (Attachments: # 1 Exhibit A)(Horowitz, Adam) 
(Entered: 05/06/2009) 
05/11/2009 
86 Defendant's MOTION Require Plaintiff to Use Proper Case Style by Jeffrey 
Epstein. (Critton, Robert) (Entered: 05/11/2009) 
05/13/2009 
81 RESPONSE/REPLY to 74 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 
88 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-ov-80119-KAM et al. (ir) 
(Entered: 05/14/2009) 
05/14/2009 
89 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 
90 ORDER denying as moot $6 Motion. See Order consolidating cases.. Signed 
by Judge Kenneth A. Marra on 5/14/2009. (Ic3) (Entered: 05/14/2009) 
05/14/2009 
91 ORDER terminating 52 Motion to Stay; terminating 84 Motion to Compel. 
See Order consolidating cases. See procedural motions pending: DE 65 and 
DE 91 in 08-80119.. Signed by Judge Kenneth A. Marra on 05/15/2009. (1c3) 
(Entered: 05/14/2009) 
05/18/2009 
92 Defendant's 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 
93 Defendant's MOTION to Strike Cases from Current Trial Docket by Jeffrey 
Epstein. Responses due by 6/8/2009 (Attachments: 14 1 Exhibit A)Associated 
Cases: 9:08-cv-80119-KAM et al.(Pike, Michael) (Entered: 05/19/2009) 
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05/19/2009 
24 MOTION Motion for Leave to Withdraw as Co-Counsel by Jeffrey Epstein. 
(Attachments: # .1 Text of Proposed Order)(Tein, Michael) (Entered: 
05/19/2009) 
05/20/2009 
95 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-ICAM; 
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-ICAM. Signed by Judge Kenneth A. Marra on 
5/20/2009. (1c3) (Entered: 05/20/2009) 
05/20/2009 
96 Clerks Notice of Docket Correction and Instruction to Filer re 91 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 
97 Clerks Notice of Docket Correction and Instruction to Filer re 94 MOTION 
Motion for Leave to Withdraw as Co-Counsel filed by Jeffrey Epstein. Error -
Wrong Event Selected;. Instruction to Filer - In the future, please select the 
proper event, i.e. Motion to Withdraw as Attorney. It is not necessary to refile 
this document. (Is) (Entered: 05/20/2009) 
05/20/2009 
2.$ NOTICE by C.M.A. of Filing Withdrawal of Previously Raised Objections to 
Defendant, Jeffrey Epstein's Motion to Compel And/Or Identify C.M.A. in the 
Style of This Case and Motion to Identify C.M.A. in Third-Party Subpoenas 
for Purposes of Discovery, Or, Alternatively, Motion to Dismiss Sua Sponte, 
With Inorporated Memorandum of Law Associated Cases: 9:08-cv-80119-
1CAM et al.(Hill, Jack) (Entered: 05/20/2009) 
05/20/2009 
99 ORDER STRIKING in all Epstein cases EXCEPT case no. 08-80119: Notice 
by C.M.A. of Filing Withdrawal of Previously Raised Objections to Epstein's 
Motion to Compel and/or Identify. This Notice should only be filed in 08-
80119, not in all of the Epstein cases.. Signed by Judge Kenneth A. Marra on 
5/20/2009. Associated Cases: 9:08-cv-80119-ICAM et al. (1c3) (Entered: 
05/20/2009) 
05/21/2009 
100
Plaintiff's 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 Doc No. 
3. Associated Cases: 9:08-cv-80119-ICAM et al.(Mermelstein, Stuart) 
(Entered: 05/21/2009) 
05/22/2009 
101 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-ICAM; terminating (101) Motion for 
Extension of Time to Respond in case 9:08-cv-80381-ICAM; 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-
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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. (1c3) (Entered: 05/22/2009) 
05/27/2009 
102 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-KAM) 
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: # I Text of Proposed 
Order)Associated Cases: 9:08-cv-80119-1CAM et al.(Horowitz, Adam) 
(Entered: 05/27/2009) 
05/28/2009 
103 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-ev-80119-KAM et al. (1c3) (Entered: 05/28/2009) 
05/29/2009 
1.04 NOTICE of Attorney Appearance by 
on behalf of 
United i
 S ales of America Associated Cases: 9:08-cv-80119-KAM et al. 
M) (Entered: 05/29/2009) 
05/29/2009 
105 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-ICAM) Defendant's 
MOTION to Stay re (50) Amended Complaint, (24 in 9:08-cv-80893-KAM) 
Defendant's MOTION to Stay re (1) Complaint, (23 in 9:08-cv-80994-KAM) 
Defendant's MOTION to Stay re (18) Amended Complaint, (22 in 9:08-cv-
80993-KAM) Defendant's MOTION to Stay re (19) Amended Complaint, (65 
in 9:08-cv-80119-ICAM) Defendant's MOTION to Stay re (56) Amended 
Complaint, (68 in 9:08-cv-80381-KAM) 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 
Atalipie, 
6/8/2009. Associated Cases: 9:08-cv-80119-KAM et 
al. 
=) 
(Entered: 05/29/2009) 
05/29/2009 
11/2
RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's 
MOTION to Compel Identifr Doe in Style of Case and in Third-Party 
Subpoenas, (91 in 9:08-cv-80119-ICAM) Defendant's MOTION to Compel 
Identity of Doe in Style of Case and Third-Party Subpoenas (replaces Docket 
entry 90) filed by Jane Doe No. 102, Jane Doe No. 101. Associated Cases: 
9:08-cv-80119-ICAM et al.(Ezell, Katherine) (Entered: 05/29/2009) 
05/29/2009 
107 ORDER STRIKING (124 in 9:08-cv-80119-ICAM, 105 in 9:08-cv-80811-
KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in 9:08-
cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-ICAM, 25 
in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-80656-
KAM, 107 in 9:08-cv-80381-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-
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KAM et al. (Ic3) (Entered: 05/29/2009) 
05/29/2009 
1.Q$ 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 
109 MOTION for Hearing MOTION TO RESCHEDULE HEARING by Jane Doe 
No. 102, Jane Doe No. 101. Associated Cases: 9:08-cv-80119-ICAM et al. 
(Josefsberg, Robert) (Entered: 05/29/2009) 
06/01/2009 
110 ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-KAM, 77 in 9:08-
cv-80993-KAM, 38 in 9:09-cv-80591-ICAM, 110 in 9:08-cv-80381-ICAM, 63 
in 9:08-cv-80994-KAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv-80811-
KAM) Motion to Continue Hearing filed by Jane Doe No. 102, Jane Doe No. 
101, (76 in 9:08-cv-80993-ICAM, 109 in 9:08-cv-80381-KAM, 108 in 9:08-
cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv-80380-ICAM, 74 
in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-ICAM, 37 in 9:09-cv-80591-
KAM, 107 in 9:08-cv-80811-KAM, 27 in 9:09-cv-80469-KAM) Motion for 
Leave to File, filed by Jane Doe No. 102, Jane Doe No. 101. THESE 
DOCUMENTS SHOULD BE FILED ONLY IN 08-80119. SEE CASE 
MANAGEMENT ORDER.. Signed by Judge Kenneth A. Marra on 6/1/2009. 
(Ic3) (Entered: 06/01/2009) 
06/01/2009 
• 
Reset Scheduling Order Deadlines: Calendar Call set for 5/28/2010 10:00 AM 
in West Palm Beach Division before Judge Kenneth A. Marra., Jury Trial set 
for 6/1/2010 09:00 AM in West Palm Beach Division before Judge Kenneth 
A. Marra., Discovery due by 12/11/2009., Dispositive Motions due by 
1/8/2010. (ir) (Entered: 06/01/2009) 
06/04/2009 
111 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 Plaintiff* 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 
112 ORDER STRIKING (112 in 9:08-cv-80381-KAM, 111 in 9:08-cv-80232-
KAM, 136 in 9:08-cv-80119-ICAM, 111 in 9:08-cv-80811-ICAM, 128 in 9:08-
cv-80380-ICAM, 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-ICAM, 32 in 9:09-cv-80469-
KAM, 79 in 9:08-cv-80993-KAM) Reply to Response to Motion, filed by 
Jane Doe No. 102, Jane Doe No. 101 Document stricken for failure to follow 
Court's orders. DO NOT FILE A DOCUMENT IN EVERY EPSTEIN CASE 
if it is to be filed only in 08-80119. See Case Management Order and contact 
CM/ECF Support for assistance in proper filing.. Signed by Judge Kenneth A. 
Marra on 6/4/2009. Associated Cases: 9:08-cv-80119-KAM et al. (1c3) 
(Entered: 06/04/2009) 
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06/08/2009 
111 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-
KAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/08/2009 
114 NOTICE by Jane Doe re (113 in 9:08-ev-80119-1CAM) Plaintiff's MOTION 
Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-Contact Order 
-Plaint¶s Jane Does 2-7 Notice ofJoinder Associated Cases: 9:08-cv-80119-
1CAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/09/2009 
115 Unopposed MOTION to Amend/Correct 61 Answer to Amended Complaint 
by Jeffrey Epstein. Responses due by 6/26/2009 (Attachments: # I Exhibit 
"A", # 2 Exhibit "B", # 3 Text of Proposed Order Order)(Pike, Michael) 
(Entered: 06/09/2009) 
PACER Service Center 
Transaction Receipt 
06/09/2009 
16:24:39 
PACER Login: du4480 
Client Code: 
Description: 
Docket Report Search Criteria: 
• 
4 -80232- 
ZA081t4
Billable Pages: 10 
Cost: 
0.80 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80232-MARRA-JOHNSON 
JANE DOE NO. 3 
Plaintiff, 
JEFFREY EPSTEIN 
Defendant. 
DEFENDANT'S, EPSTEIN, MOTION TO DISMISS AND MOTION FOR MORE 
DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPLAINT 
Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves 
to dismiss and for more definite statement of Plaintiff JANE DOE NO. 3's Amended 
Complaint. Rules 12(b)(6), and 12(e) and (f), Fed.R.Civ.P. (2008). In support of his 
motion, Defendant states: 
Introduction 
Defendant is filing similar motions to dismiss and for more definite statement 
directed to the Amended Complaints filed against Defendant in this Court in JANE DOE 
NO. 2, JANE DOE NO. 3, JANE DOE NO. 4 and JANE DOE NO. 5. The motions are 
directed to the Counts for "Sexual Assault and Battery," and "Coercion and Enticement 
to Sexual Activity in Violation of 18 U.S.C. §2422" in each of the respective complaints. 
However, there are distinctions in the four motions filed based on the complaint 
allegations. For example, Defendant challenges the Plaintiffs' allegations as to assault 
in all four actions, and challenges the battery allegations in JANE DOE NOS. 2 and 3, 
but not in JANE DOE NOS. 4 and 5. Defendant moves to dismiss the §2422 count in all 
four actions. 
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Case No. CV-80232-Marra-Johnson 
Page No. 2 
Motion 
1. Counts I and III of the Amended Complaint are required to be dismissed for 
failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has 
failed to allege sufficient factual allegations in the Counts and instead alleges labels and 
conclusions, and an attempted formulaic recitation of the elements in each Count. 
2. In the alternative, Defendant seeks more definite statement of Count I and III. In 
Count I, the Plaintiff is required to more definitely allege what was done to her; what 
EPSTEIN said and did, if anything, to create fear and apprehension in Plaintiff; what 
was the intentional offensive or harmful contact in pleading the elements of assault and 
battery. In Count III, Plaintiff is required to more definitely state the underlying factual 
allegations to support her claim as set forth in the statute, 18 U.S.C. §2422(b) and 
§2455. Rule 12(e). See discussion of law below herein. 
3. Also, Plaintiffs reference in Count III to 28 U.S.C. §2255, pertaining to habeas 
corpus proceedings is required to be stricken as immaterial. Rule 12(f). Plaintiff is 
required to more definitely state what statutory provision she is relying on. Rule 12 (e). 
WHEREFORE, Defendant respectfully requests that this Court dismiss Counts I and 
III, strike the immaterial statutory reference, and require Plaintiff to more definitely plead 
the underlying elements of her claims. 
SupportIna Memorandum of Law 
Standard on Rule 12(b)(6) Motion To Dismiss 
As established by the Supreme Court in Bell Atlantic Corp.'. 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 
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in the complaint must state "more than labels and conclusions, and a formulaic 
recitation of the elements of a cause of action will not do." Id, at 1965. Further, "[f]actual 
allegations must be enough to raise a right to relief above the speculative level ... on the 
assumption that all the allegations in the complaint are true (even if doubtful in fact)." Id. 
On a motion to dismiss, the well pleaded allegations of plaintiffs complaint are taken as 
true and construed in the light most favorable to the plaintiff. 
DeKalb Count 
Sch. Dist. 446 F.3d 1153, 1156 (11th Cir.2006). 
Significantly, the Supreme Court in Bell Atlantic Corp.,. Twombly abrogated the 
often cited observation that "a complaint should not be dismissed for failure to state a 
claim unless it appears beyond doubt that the plaintiff can prove not set of facts in 
support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley 
I. Gibson 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme 
Court rejected the notion that "a wholly conclusory statement of claim [can] survive a 
motion to dismiss whenever the pleadings le[ave] open the possibility that a plaintiff 
might later establish some 'set of [undisclosed] facts' to support recovery." Id. As 
explained by the Supreme Court in Bell Atlantic Corp., supra at 1664-65: 
While a complaint attacked by a Rule 12(b)(6) moti
 to dismiss does not 
need detailed factual allegations ibid.: Sanivan I. American Bd. of 
Psychiatry and Neurology. Inc. 40 F.3d 247, 251 (C.A.7 1994), a plaintiff's 
obligation to provide the "grounds" of his "entitle[ment] to relief' requires 
more than labels and conclusions, and a formuiic recitation of the elements 
of a cause of action will not do, see Papasan . Allain, 478 U.S. 265, 286, 
106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are 
not bound to accept as true a legal conclusion couched as a factual 
allegation"). Factual allegations must be enough to raise a right to relief 
above the speculative level, see 5 C. Wright & A. Miller, Federal Practice and 
Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller) 
C[T]he pleading must contain something more ... than ... a statement of facts 
that merely creates a suspicion [of] a legally cognizable right of action"), on 
the assumption that all the allegations in the complaint are true (even if 
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doubtful in fact), see, e.g., Swierkiewiczt. Sorem N. A., 534 U.S. 506, 508, 
n. 1, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002); Neitzkelt. Williams, 490 U.S. 319, 
327, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1989) (" Rule 12(b)(6) does not 
countenance ... dismissals ivsed on a judge's disbelief of a complaint's 
factual allegations"); Scheueri. 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"). 
Pursuant to Rule 12(e), a party may move for more definite statement of a 
pleading to which a responsive pleading is allowed where the pleading "is so vague or 
ambiguous that the party cannot reasonably frame a response." The motion is required 
to point out the defects and the desired details. Id. 
Count I — "Sexual Assault and Battery" is subject to dismissal as Plaintiff has 
failed to state a claim upon which relief can be granted. 
It is well settled that this Court is to apply Florida substantive law in this action. 
Erie R.Co.l. Tompkins 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term 
"assault and battery" is most commonly referred to as if it were a legal unit, or a single 
concept, "assault and battery are separate and distinct legal concepts, assault being the 
beginning of an act which, if consummated, constitutes battery." 3A Fla.Jur.2d Assault 
§1. An assault and battery are intentional acts. See generally, Spivey. Battaglia 258 
So.2d 815 (Fla. 1972); and Travelers Indem. Co... PCR, Inc., 889 So.2d 779 (Fla. 
2004). 
An "assault" is an intentional, unlawful offer of corporal injury to another by force, 
or exertion of force directed toward another under such circumstances as to create a 
reasonable fear of imminent peril. See Lay 
Kremer, 411 So.2d 1347 (Fla. 1st DCA 
1982). It must be premised upon an affirmative act - a threat to use force, or the actual 
exertion of force. See 3A Fla.Jur.2d Assault §1("The essential element of the tort of 
assault is the violence offered, and not actual physical contact."). 
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case 9:08-cv-I. 
)2-KAM 
Document 41 
Enterer 
FLSD Docket 10/C 
)8 
Page 5 of 10 
Case No. CV-80232-Marra-Johnson 
Page No. 5 
Tort of "battery" consists of the infliction of a harmful or offensive contact upon 
another with the intent to cause such contact or the apprehension that such contact is 
imminent. Quilling/. Price 894 So.2d 1061 (Fla. 5th DCA 2005); Sullivan/. Atlantic 
Federal Savings & Loan 454 So.2d 52 (Fla. 4th DCA 1984)("a battery consists of the 
intentional infliction of a harmful or offensive contact upon the person of another"). See 
3A Fla.Jur.2d Assault §1. 
With the standard of pleading established in Twomblv, supra, in the context of 
the elements for assault and battery, Plaintiff has failed to state a claim upon which 
relief can be granted. Rule 12(b)(6). As to the elements of assault, here are no factual 
allegations as to what was said or done to Plaintiff such that it constituted an 
"intentional, unlawful offer of corporal injury to another by force, or exertion of force 
directed toward another under such circumstances as to create a reasonable fear of 
imminent peril." See ¶12 of Am. Comp. The same is true for the claim of battery. 
Plaintiff makes the general allegation in ¶12 that "he (Defendant) laid down on the 
massage table, and sexually assaulted Jane during the massage." Under applicable 
law, Plaintiff is required to give more than labels and conclusions, and a formulaic 
recitation of the elements of a cause of action. Twombly, supra. Plaintiff is required to 
allege the facts of what was done to her; what EPSTEIN said and did, if anything, to 
create fear and apprehension in Plaintiff; what was the intentional offensive or harmful 
contact? 
As noted in the introduction and as this Court is well aware, there is more than 
one action brought against this Defendant attempting to allege similar sounding claims. 
With all due respect, the details as to a particular claim asserted by a particular Plaintiff 
EFTA00175736