EFTA00175214

Case 9:09-cv-80656-KAM 
Document 5 
Entered on FLSD Docket 05/11/2009 
Page 1 of 12 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 09-80656-CIV-Ryskamp 
JANE DOE No. 102, 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant, 
RESPONSE IN OPPOSITION TO MOTION TO PROCEED ANONYMOUSLY 
AND 
EPSTEIN'S MOTION TO COMPEL AND/OR IDENTIFY JANE DOE #102 IN 
THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE #102 IN 
THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY, WITH 
INCORPORATED MEMORANDUM OF LAW 
Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and 
through his undersigned attorneys, hereby files his Response In Opposition to 
Plaintiff, Jane Doe #102's Motion to Proceed Anonymously and files his Motion 
requesting that this Court enter an order identifying in the style of this case the 
complete legal name of the Plaintiff, JANE DOE #102 ("JANE DOE"), to 
substitute her complete legal name In this case in place of "JANE DOE" and, 
equally important, allowing Defendant to identify her in various subpoenas that 
Epstein must serve so Epstein can defend this case. In support, Mr. Epstein 
states as follows: 
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Document 5 
Entered on FLSD Docket 05/11/2009 
Page 3 of 12 
denied, but Epstein's Motion to Identify Jane Doe must be granted. Despite 
Plaintiff's allegations in the Motion to Proceed Anonymously, this Court has not 
"allowed" any Plaintiff to proceed anonymously. Quite simply, that is the way 
each Plaintiff chose to file each of their respective cases, all of which are 
currently being challenged in those other matters by Motion to Identify. 
4. 
Importantly, JANE DOE claims that she has and will suffer ". . 
.physical injury, pain and suffering, emotional distress, psychological and 
psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss 
of educational opportunities, loss of self-esteem, loss of dignity, invasion of her 
privacy, separation from her family . . . , and medical and psychological 
expenses. . . , loss on income, loss of the capacity to earn income In the future, 
and loss of the capacity to enjoy life" ¶¶28, Comp. DE 1; see also ¶¶36, 40, 44, 
48, 52, 56, 61, 65, and 69, Comp., DE 1. 
5. 
Epstein has a constitutional due process right to defend himself and 
to seek the production of information that will assist in his defense of the 
allegations in the Complaint. In this case, Plaintiffs counsel intends on serving 
subpoenas on Plaintiffs treating physicians and other third parties. Thus, this 
motion seeks not only a denial Plaintiffs Motion to Proceed Anonymously but to 
Identify JANE DOE In the style of this case and to identify JANE DOE in various 
third-party subpoenas for discovery purposes. 
6. 
The undersigned's experience In "Jane Doe" lawsuits is that once a 
Plaintiff is identified, other individuals come forward in the discovery phase with 
information which often directly contradicts allegations as to the events and 
3 
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agreed that the subpoenas filed with the clerk would be redacted. Several 
attorneys agreed to this procedure in those cases. In Federal Court, subpoenas 
are not filed with the clerk. Thus, In this matter, the undersigned offered to serve 
the third-party subpoenas with plaintiff's full name, date of birth and social 
security number (last four digits) and would agree to redact any identifying 
information on any documents filed with this court if that ultimately became 
necessary. 
9. 
Moreover, when an order from the court is attached to the 
Subpoena, treaters and other third parties produce the records and show up to 
the depositions with the records requested because the deponent knows what to 
bring by virtue of knowing the identity of the Plaintiff. 
10. 
Epstein's counsel intends to serve and depose witnesses duces 
tecum. If Epstein is not permitted to identify JANE DOE (thus allowing her to 
proceed anonymously), how will any deponent know who the parties are and 
what to bring to the deposition pursuant to the duces tecum? Further, how will 
Epstein be able to defend the claims. Just like the Plaintiff, Epstein is entitled to 
due process. If the Court allows Jane Doe to proceed anonymously, Jane Doe 
will be permitted to present her case and Epstein will be limited in his defenses. 
11. 
While it is within the sound discretion of this court to allow a party to 
proceed anonymously, Plaintiff should not attempt to utilize that discretion as a 
shield from legitimate and necessary discovery. Epstein has a fundamental due 
process right to conduct discovery. 
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b. 
whether the party defending the suit would be prejudiced; 
c. 
whether the plaintiff is required to disclose information of 
utmost intimacy; 
d. 
whether the plaintiff is compelled to admit an intention to 
engage in illegal conduct, 
thereby risking 
criminal 
prosecution; 
e. 
whether the Plaintiff would risk suffering injury if identified; 
f. 
whether the interests of children are at stake; and 
g. 
whether there are less drastic means of protecting the 
legitimate interests of either party. 
Doe v. Frank 951 F.2d at 323. 
Plaintiff does not fall under any of the factors. Moreover, even If she did 
meet one of the factors, "[t]he fact that [a] Doe [Plaintiff] may suffer some 
personal embarrassment, standing alone, does not require the granting of a 
request to proceed under a pseudonym." Id' see also Doe v. Rostker, 89 F.R.D. 
159 (N.D. Calif. 1981). Any substantial privacy interests JANE DOE has must 
outweigh the customary and constitutionally embedded presumption of openness 
to judicial proceedings. Doe v. Frank, 951 F.2d at 323; Doe v. Berostron, 2009 
WL 528623 (C.A.9(Or.))(denying request to proceed anonymously in civil action 
by Plaintiff where Plaintiff's arrest, prosecution and acquittal were matters of 
public record). 
14. 
In Sweetland v. State, 535 So.2d 646 (Fla. 1st DCA 1988), the court 
reasoned that the purpose of discovery is to eliminate the likelihood of surprise 
and to Insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 
1.280(b)(1)• see also Surf Drugs. Inc.. v. Vermette 236 So.2d 108, 111 (Fla. 
7 
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Case 9:09-cv-80656-KAM 
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Entered on FLSD Docket 05/11/2009 
Page 9 of 12 
damages. Plaintiff is claiming emotional/psychological damages. 
Therefore, 
Epstein is entitled to know her psychological condition(s) before and after the 
alleged incident(s) she references in the Complaint. In particular, JANE DOE 
alleges specific disorders as a result of Epstein's alleged conduct — suffer 
. 
.physical injury, pain and suffering, emotional distress, psychological and 
psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss 
of educational opportunities, loss of self-esteem, loss of dignity, invasion of her 
privacy, separation from her family . . . , and medical and psychological 
expenses. . . , loss on income, loss of the capacity to earn income in the future, 
and loss of the capacity to enjoy life." (Emphasis Added). See supra. Epstein is 
also entitled to know, among other things, whether she had any physical 
complaints or whether there was ever any evidence of physical battery on JANE 
DOE's body from the acts she complains of in the Complaint. The need to serve 
third-party subpoenas on medical doctors is a basic discovery need related to the 
claims alleged by JANE DOE for which Plaintiff's counsel refuses to compromise. 
Balas v. Ruzzo 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 
(Fla. 1998)(discoverability of Plaintiff's history of sexual activity is relevant to 
damages); United States v. Bear Stops 997 F.2d 451 (81h Cir. 1993)(deals with 
"admissibility of other acts of sexual abuse by individuals other than the 
defendant to explain why a victim of abuse exhibited behavioral manifestations of 
a sexually abused child.") 
If Plaintiff saw a psychologist or other physician 
during or after the time periods she claims she was assaulted by Epstein but 
either did not discuss or did discuss the incidents (or lack thereof) would be 
9 
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Case 9:09-cv-80656-KAM 
Document 5 
Entered on FLSD Docket 05/11/2009 
Page 11 of 12 
was charged with any crimes. If Jane Doe was charged with crimes, Epstein is 
entitled to obtain certified copies of those crimes Plaintiff may have committed for 
purposes of discovery and impeachment. Questions will be asked regarding 
those crimes (e.g., Have you been convicted of a crime of dishonesty or false 
statement? If so, how many times? Have you been convicted of a felony? If so, 
how many times?) To hold otherwise would not only prevent broad discovery but 
would ultimately result in reversible error at any trial. 
II. Conclusion and Prayer for Relief 
22. 
Epstein requests the following relief: 
a. 
That JANE DOE's Motion to Proceed Anonymously be denied; 
b. 
That this Court grant Epstein's Motion and that JANE DOE be 
identified by her legal name in the style of this case; and 
c. 
That Epstein be granted leave to identify JANE DOE by her 
legal name in Third-Party Subpoenas (but not file them in Court 
or, if required, in a redacted form). 
WHEREFORE, Epstein, Jeffrey Epstein, respectfully requests that this 
Court enter said order granting the relief requested above, and for such other 
and further relief as this Court may deem just and proper. 
By: 
ROBERT D. C ITTON, JR., ESQ. 
MICHAEL J. PIKE, ESQ. 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was electronically 
filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing 
document is being served this day on all counsel of record identified on the 
following Service List in the manner specified by CM/ECF on this _EL day of 
Mav, 2009 
11 
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AEV 
U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE #: 9:09-cv-80656-KAM 
Doe No. 102 v. Epstein 
Assigned to: Judge Kenneth A. Marra 
Lead case: 9:08-cv-80119-KAM 
Member case: (View Member Case) 
Cause: 28:1391 Personal Injury 
Plaintiff 
Jane Doe No. 102 
V. 
Defendant 
Jeffrey Epstein 
Date Filed: 05/01/2009 
Jury Demand: Plaintiff 
Nature of Suit: 360 P.I.: Other 
Jurisdiction: Federal Question 
represented by Katherine Warthen Ezell 
Podhurst Orseck Josefsberg et al 
City National Bank Building 
25 W Flagler Street 
Suite 800 
Miami FL 33130-1780 
Fax: 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Robert C. Josefsberg 
Podhurst Orseck Josefsberg et al 
City National Bank Building 
25 W Flagler Street 
Suite 800 
Miami FL 33130-1780 
Fax: 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
represented by Robert Deweese Critton , Jr. 
Burman Critton Luttier & Coleman 
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515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Amicus 
United States of America 
represented by 
Fax: 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
United States Attorney's Office 
500 East Broward Blvd 
7th Floor 
Ft Lauderdale , FL 33394 
xt. 3546 
Fax: 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Date Filed 
# dear Docket Text 
05/01/2009 
1 r 
COMPLAINT and Demand for Jury Trial against Jeffrey Epstein. Filing fee 
$350.00. Receipt No. 100030, filed by Jane Doe No. 102.(caw) (Entered: 
05/04/2009) 
05/01/2009 
2 r Summons Issued as to Jeffrey Epstein. (caw) (Entered: 05/04/2009) 
05/01/2009 
3 
Sealed Document. (igo) (Entered: 05/04/2009) 
05/01/2009 
4 
Sealed Document. (igo) (Entered: 05/04/2009) 
05/11/2009 
5 
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RESPONSE/REPLY to 4 Sealed Document, 3 Sealed Document 
Opposition to Motion to Proceed Anonymously by Jeffrey Epstein. (Critton, 
Robert) (Entered: 05/11/2009) 
05/11/2009 
6 
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NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf 
of Jeffrey Epstein (Critton, Robert) (Entered: 05/11/2009) 
05/11/2009 
7 
MOTION to Compel and/or identify Jane doe #102 in the style of this case 
( Responses due by 5/29/2009), MOTION to identify jane doe #102 in the 
third-party subpoenas for purposes of discovery, with incorporated 
memorandum of law by Jeffrey Epstein.(see docket entry 5 for image) (tas) 
(Entered: 05/12/2009) 
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05/12/2009 
8 
Clerks Notice of Docket Correction and Instruction to Filer re 5 
Response/Reply (Other) Error - Two or More Document Events Filed as 
One; Correction - Additional event(s) 7 MOTION to Compel and/or 
identift Jane doe #102 in the style of this case MOTION to identify jane 
doe #102 in the third-party subpoenas for purposes of discovery, with 
incorporated memorandum of law. docketed by Clerk. Instruction to Filer -
In the future, please select all applicable events. It is not necessary to refile 
this document. (tas) (Entered: 05/12/2009) 
05/13/2009 
9 
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ORDER of Transfer/REASSIGNING CASE. Case reassigned to Judge 
Kenneth A. Marra for all further proceedings. Senior Judge Kenneth L. 
Ryskamp no longer assigned to case. Signed by Senior Judge Kenneth L. 
Ryskamp on 5/12/2009. (tas) (Entered: 05/14/2009) 
05/14/2009 
Cases associated. (ir) (Entered: 05/14/2009) 
05/14/2009 
10 
n 
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-KAM et 
al. (ir) (Entered: 05/14/2009) 
05/14/2009 
11 
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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-ICAM et al. 00 (Entered: 05/14/2009) 
05/14/2009 
12 
ORDER terminating 7 Motion to Compel; terminating 7 Motion. See Order 
consolidating cases. See procedural motions pending: DE 91 in 08-80119.. 
Signed by Judge Kenneth A. Marra on 5/14/2009. (1c3) (Entered: 
05/14/2009) 
05/20/2009 
13 
n 
NOTICE by
 Filing Withdrawal of Previously Raised Ob'ections 
to Defendant, Jeffrey Epstein's Motion to Compel And/Or Identi 
in the Style of This Case and Motion to Identify 
. in Third- arty 
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 
14 
ORDER S
G in all Epstein cases EXCEPT case no. 08-80119: 
Notice by M. 
of Filing Withdrawal of Previously Raised Objections to 
Epstein's Motion to Compel and/or Identify. This Notice should only be 
filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth 
A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-KAM et al. (1c3) 
(Entered: 05/20/2009) 
05/22/2009 
15 
Clerks Notice of Docket Correction and Instruction to Filer re 11 Notice 
(Other), Notice (Other) filed by 
.. Error - Incorrect Document 
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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) 
05/26/2009 
16 
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Plaintiffs MOTION to Preserve Evidence Plaintiffs Jane Doe No. 101 and 
Jane Doe No. 102's Motion for an Order for the Preservation of Evidence 
and Incorporated Memorandum of Law by Jane Doe No. 101, Jane Doe No. 
102. (Attachments: # 1 Exhibit "A", # 2 Exhibit "B", # 3 Text of Proposed 
Order)Associated Cases: 9:08-cv-80119-KAM, 9:09-cv-80591-KAM, 9:09-
cv-80656-KAM(Ezell, Katherine) (Entered: 05/26/2009) 
05/27/2009 
17 
ORDER terminating(28) Motion to Preserve Evidence in case 9:09-cv-
80591-KAM; terminating(16) Motion to Preserve Evidence in case 9:09-
cv-80656-KAM This motion is pending ONLY in case no. 08-80119.. 
Signed by Judge Kenneth A. Marra on 5/27/2009. (1c3) (Entered: 
05/27/2009) 
05/27/2009 
18 
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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-ICAM) 
Defendant's MOTION to Compel Identity of Doe in Style of Case and 
Third-Party Subpoenas (replaces Docket entry 90) (Attachments: # 1 Text 
of Proposed Order)Associated Cases: 9:08-cv-80119-KAM et al.(Horowitz, 
Adam) (Entered: 05/27/2009) 
05/28/2009 
19 
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 
20 
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NOTICE of Attorney Appearance by 
on behalf of 
United States of America Associated Cases: 9:08-cv-80 119-KAM et al. 
, 
IM) (Entered: 05/29/2009) 
05/29/2009 21 
n 
RESPONSE to Motion re (72 in 9:08-cv-80380-KAM) Defendant's 
MOTION to Stay re (62) Amended Complaint, (57 in 9:08-cv-80232-
KAM) Defendant's MOTION to Stay re (50) Amended Complaint, (24 in 
9:08-cv-80893-KAM) Defendant's MOTION to Stay re (1) Complaint, (23 
in 9:08-cv-80994-KAM) Defendant's MOTION to Stay re (18) Amended 
Complaint, (22 in 9:08-cv-80993-KAM) 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-
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 America. 
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Rtlue17.6/8/2009. Associated Cases: 9:08-cv-80119-ICAM et al. 
(
, M =) 
(Entered: 05/29/2009) 
05/29/2009 
22 
RESPONSE in Opposition re (90 in 9:08-cv-80119-ICAM) 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 
23 
ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
ICAM, 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-KAM, 
25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-
80656-1CAM, 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. (Ic3) (Entered: 05/29/2009) 
05/29/2009 
24 
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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-ICAM et al.(Ezell, 
Katherine) (Entered: 05/29/2009) 
05/29/2009 
25 r 
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 
26 
ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-KAM, 77 in 9:08-
cv-80993-KAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-KAM, 
63 in 9:08-cv-80994-KAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv-
80811-KAM) Motion to Continue Hearing filed by Jane Doe No. 102, Jane 
Doe No. 101, (76 in 9:08-cv-80993-ICAM, 109 in 9:08-cv-80381-KAM, 
108 in 9:08-cv-80232-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 
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. (1c3) (Entered: 06/01/2009) 
06/04/2009 
27 
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REPLY to Response to Motion re (113 in 9:08-cv-80119-ICAM) Plaintiffs 
MOTION Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-
Contact Order Plaints Jane Doe No. 101 and Jane Doe No. 102's Reply 
to Defendant Jeffrey Epstein's Response to Plaintiffs Jane Doe No. 101 and 
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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 
28 
ORDER STRIKING (112 in 9:08-cv-80381-ICAM, 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-KAM, 79 in 9:08-cv-80893-
KAM, 42 in 9:09-cv-80591-KAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09-
cv-80469-KAM, 79 in 9:08-cv-80993-ICAM) Reply to Response to Motion, 
filed by Jane Doe No. 102, Jane Doe No. 101 Document stricken for failure 
to follow Courts 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) 
06/08/2009 
29 
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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 
30 
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NOTICE by Jane Doe 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 Does 2-7 Notice of Joinder Associated Cases: 9:08-
cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/10/2009 
31 
Clerks Notice of Docket Correction and Instruction to Filer re 29 Response 
to Motion, filed by Jane Doe. Error - Document Incomplete, i.e. Missing 
Page 1 on Attachments: #2 Exhibit B . (Is) (Entered: 06/10/2009) 
06/10/2009 
32 
Clerks Notice of Docket Correction and Instruction to Filer re 30 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. (ls) (Entered: 
06/10/2009) 
View Selected 
or 
Download Selected 
PACER Service Center 
Transaction Receipt 
06/10/2009 14:37:13 
PACER 
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Client Code: 
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it 
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Case 9:08-cv-80993-KAM 
Document 19 
Entered on FLSD Docket 02/27/2009 
Page 1 of 8 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08- 80993-CIV-MARRA/JOHNSON 
JANE DOE NO. 7, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
AMENDED COMPLAINT 
Plaintiff, Jane Doe No. 7 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey 
Epstein, as follows: 
Parties, Jurisdiction and Venue 
1. 
Jane Doe No. 7 is a citizen and resident of the State of Florida, and is sui juris. 
2. 
This Complaint is brought under a fictitious name to protect the identity of the 
Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a 
minor. 
3. 
Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 
4. 
This is an action for damages in excess of $50 million. 
5. 
This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 
U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs; 
and (ii) is between citizens of different states. 
6. 
Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because 
Plaintiff alleges a claim under the laws of the United States. This Court has supplemental 
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generally $200 to $300 per "massage" session - and who were perceived as less likely to complain to 
authorities or have credibility if allegations of improper conduct were made. This was an important 
element of Epstein's plan. 
12. 
Epstein's plan and scheme reflected a particular pattern and method. The underage 
victim would be brought to Epstein's mansion, where she would be introduced to
Epstein's assistant. Mould
then bring the girl up a flight of stairs to a bedroom that 
contained a massage table in addition to other furnishings. The girl would then find herself alone in 
the room with Epstein, who would be wearing only a towel. He woulddirect he rigl to give him a 
massage. Epstein would then perform one or more lewd, lascivious and sexual acts, including 
13. 
Consistent with the foregoing plan and scheme, when Jane Doe was 16 years old, she 
was recruited by=It
 o give Epstein a massage for monetary compensation. Jane was 
brought to Epstein's mansion in Palm Beach. Once there, Jane was introduced to 
all 
who led her up the flight of stairs to the room with the massage table. In this room, Jane was 
directed by Epstein to give him a massage. During this massage, Epstein sexually assaulted Jane and 
Epstein then paid Jane money. 
14. 
Jane returned on many occasions to the Palm Beach mansion to provide Epstein with 
massages for money. On those occasions, Epstein engaged in sexual contact and activity with Jane, 
which included, among other things, Epstein touching Jane's 
placing 
on her 
his sexual abuse continued over a period of approximately 18-24 
months. 
15. 
As a result of these encounters with Epstein, Jane experienced confusion, shame, 
humiliation and embarrassment, and has suffered severe psychological and emotional injuries. 
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in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health 
to be significantly impaired. 
26. 
Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had 
reason to know that his intentional and outrageous conduct would cause emotional distress and 
damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing 
severe emotional distress to Jane Doe. 
27. 
As a direct and proximate result of Epstein's intentional or reckless conduct, Jane 
Doe, has suffered and will continue to suffer severe mental anguish and pain. 
WHEREFORE, Plaintiff Jane Doe No. 7 demands judgment against Defendant Jeffrey 
Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this 
Court deems just and proper. 
COUNT III 
Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. ti2422 
28. 
Plaintiff Jane Doe repeats and realleges paragraphs 1 through I5 above. 
29. 
Epstein used a facility or means of interstate commerce to knowingly persuade, 
induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or 
sexual activity for which any person can be charged with a criminal offense. 
30. 
On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07 
and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
00938 I AXX XMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and 
scheme as alleged herein. 
31. 
As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of 
Florida Statute §796.07(2) (including subsections (c), (d), (e), (f), (g), and (h) thereof), and other 
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Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those 
parties who are not authorized to receive electronically Notices of Electronic Filing. 
/s/ Adam D. Horowitz 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80993-MARRA-JOHNSON 
JANE DOE NO. 7 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
DEFENDANT EPSTEIN'S FIRST AMENDED ANSWER & AFFIRMATIVE 
DEFENSES TO PLAINTIFF'S (FIRST) AMENDED COMPLAINT 
Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his 
undersigned attorneys, files his Answer to Plaintiff's Amended Complaint [DE 19] and 
states: 
1. Without knowledge and deny. 
2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment 
privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d 
1099 (Fla. 4th DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth 
Amendment's Self-Incrimination Clause applies to the states through the Due Process 
Clause of the Fourteenth Amendment - "Olt would be incongruous to have different 
standards determine the validity of a claim of privilege based on the same feared 
prosecution, depending on whether the claim was asserted in state or federal court."); 5 
Fed.Prac. & Proc. Civ. ad §1280 Effect of Failure to Deny — Privilege Against Self-
Incrimination (".,.court must treat the defendant's claim of privilege as equivalent to a 
specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. - 
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Jane Doe No. 7 v. Epstein 
Page 3 
7. As to the allegations in paragraphs 7 through 15 of Plaintiff's Second Amended 
Complaint, Defendant exercises his Fifth Amendment Privilege against self-
incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4th DCA 
1983); Malloy v. Hogan 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-
Incrimination Clause applies to the states through the Due Process Clause of the 
Fourteenth Amendment - `lilt would be incongruous to have different standards 
determine the validity of a claim of privilege based on the same feared prosecution, 
depending on whether the claim was asserted in state or federal court."); 5 Fed.Prac. & 
Proc. Civ. 3d §1280 Effect of Failure to Deny — Privilege Against Self-incrimination 
("...court must treat the defendant's claim of privilege as equivalent to a specific 
denial."). See also 24 FIa.Jur.2d Evidence §592. Defendants In civil actions. —"... a civil 
defendant who raises an affirmative defense is not precluded from asserting the 
privilege [against self-incrimination], because affirmative defenses do not constitute the 
kind of voluntary application for affirmative relief' which would prevent a plaintiff bringing 
a claim seeking affirmative relief from asserting the privilege. 
8. 
In response to the allegations of paragraph 16, Defendant realleges and adopts 
his responses to paragraphs 1 through 15 of the Second Amended Complaint set forth 
in paragraphs 1 through 7 above herein. 
9. Defendant asserts the Fifth Amendment Privilege against self-Incrimination to 
the allegations set forth in paragraphs 17 through 22 of the Second Amended 
Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4Ih DCA 1983); 
Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination 
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Jane Doe No. 7 v. Epstein 
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§1280 Effect of Failure to Deny — Privilege Against Self-incrimination ("...court must 
treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24 
FIa.Jur.2d Evidence §592. Defendants In civil actions. —"... a civil defendant who raises 
an affirmative defense is not precluded from asserting the privilege [against self-
incrimination], because affirmative defenses do not constitute the kind of voluntary 
application for affirmative relief" which would prevent a plaintiff bringing a claim seeking 
affirmative relief from asserting the privilege. 
12. In response to the allegations of paragraph 29, Defendant realleges and adopts 
his responses to paragraphs 1 through 15 of the Second Amended Complaint set forth 
in paragraphs 1 through 7 above herein. 
13. Defendant asserts the Fifth Amendment Privilege against self-incrimination to 
the allegations set forth in paragraphs 30 through 35 of the Second Amended 
Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4th DCA 1983); 
Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination 
Clause applies to the states through the Due Process Clause of the Fourteenth 
Amendment - lilt would be incongruous to have different standards determine the 
validity of a claim of privilege based on the same feared prosecution, depending on 
whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d 
§1280 Effect of Failure to Deny — Privilege Against Self-Incrimination ("...court must 
treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24 
FIa.Jur.2d Evidence §592. Defendants in civil actions. —"... a civil defendant who raises 
an affirmative defense is not precluded from asserting the privilege [against self-
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