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. Case• 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 13 of 22 
COUNT FOUR 
(Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit 
Conduct pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. 2252(a)(1)) 
37. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, real leges, and incorporates by 
reference the allegations contained in paragraphs I through 24 above. 
38. 
Defendant, Jeffrey Epstein, upon information and belief, knowingly mailed, 
transported, shipped, or sent via computer and/or facsimile in or affecting interstate or foreign 
commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit 
conduct in violation of 18 U.S.C. § 2252(a)( I). As previously stated in paragraphs 14, 16, and 
34, upon information and belief, Defendant displayed a myriad of nude photographs of underage 
girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin 
Islands. Upon information and belief, many of the photographs in the possession of Defendant 
were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his 
arrest, police found two hidden cameras and photographs of underage girls on a computer in 
Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken 
lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have 
transported lewd photographs of Plaintiff (among many other victims) to his other residences and 
elsewhere using a facility or means of interstate and/or foreign commerce. Upon information 
and belief, one or more sexually explicit photographs of Plaintiff that were taken when she was a 
minor were confiscated by the Palm Beach Police Department during its execution of a search 
warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, 
those photographs are still in the custody of law enforcement. 
39. 
As previously stated in paragraph 22, any assertions by Defendant that he was 
unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by 
the provision of applicable federal and state statutes concerning the sexual exploitation and abuse 
13 
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Document 9 
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Page 15 of 22 
COUNT FIVE 
(Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. 4 2255 in 
Violation of 18 U.S.C. 4 2252A(a)(1)) 
42. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 24 above. 
43. 
Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via 
computer or facsimile in or affecting interstate and/or foreign commerce child pornography in 
violation of 18 U.S.C. § 2252A(a)(1). As previously stated in paragraph 16, Defendant displayed 
a myriad of nude photographs of underage girls throughout his homes, including his homes in 
New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and 
belief, many of the photographs in the possession of Defendant were taken with hidden cameras 
set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden 
cameras and nude photographs of underage girls on a computer in Defendant's home. Upon 
information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of 
Plaintiff, Jane Doc No. 101, with his hidden cameras and may have transported lewd 
photographs of Plaintiff (among many other victims) to his other residences and elsewhere using 
a facility or means of interstate and/or foreign commerce. Upon information and belief, one or 
more nude photographs of Plaintiff that were taken when she was a minor were confiscated by 
the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm 
Beach mansion on October 20, 2005. Upon information and belief, those photographs are still 
in the custody of law enforcement. 
44. 
As previously stated in paragraph 22, any assertions by Defendant that he was 
unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by 
the provision of applicable federal and state statutes concerning the sexual exploitation and abuse 
of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew 
15 
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Cae 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 17 of 22 
COUNT SIX 
(Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. 
2255 in Violation of 18 U.S.C. S 2252Men 
47. 
Plaintiff, Janc Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above and Counts One through 
Five. 
48. 
Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, 
as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A(g)(1). As more fully 
above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 1591 (sex 
trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 U.S.C. §§ 
2251, 2252(a)(1), and 2252(A)(a)(I)), and Chapter 117 (transportation for illegal sexual activity 
in violation of 18 U.S.C. §§ 2422, and 2423). As more fully set forth above in paragraphs 9 
through 19, Defendant's actions involved countless victims and countless separate incidents of 
abuse, and he committed those offenses against minors in concert with at least three other 
persons. 
49. 
Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
50. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
17 
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Document 9 
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Page 19 of 22 
DEMAND FOR JURY TRIAL 
Plaintiff demands to have her case tried before a jury. 
s/Katherine W. Ezell 
Robert 
Josefsberg, Bar No. 040856 
Katherine W. Ezell, Bar No. 114771 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
Miami Florida 33130 
fax 
Attorneys for Plaintiff 
19 
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Document 9 
Entered on FLSD Docket 05/01/2009 
Page 21 of 22 
SERVICE LIST 
JANE DOE NO. 101 v. JEFFREY EPSTEIN 
Case No. 08-CV-80591-MARRA/JOHNSON 
United States District Court, Southern District of Florida 
Robert Critton, Esq. 
Burman, Critton, Luttier & Coleman LLP 
515 North Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
Jack Goldberger, Esq. 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, FL 33401 
Bruce E. Reinhart, Esq. 
Bruce E. Reinhart, P.A. 
250 South Australian Avenue, Suite 1400 
West Palm Beach, FL 33401 
Phone: 
Fax: 
Co-counsel for Defendant, Jeffrey Epstein 
Jack Scarola, Esq. 
Jack P. Hill, Esq. 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Phone: 
Fax: 
[email protected] 
inh@searcvlaw,com 
Counsel for Plaintiff... 
Adam Horowitz, Esq. 
Stuart Mermelstein, Esq. 
Herman & Mermelstein 
18205 Biscayne Blvd. 
Suite 2218 
Miami, FL 33160 
21 
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Case 9:08-cv-80119-KAM 
Document 151 
Entered on FLED Docket 06/10/2009 
Page 1 of 11 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN 
Defendant. 
JANE DOE NO. 3, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN 
Defendant. 
JANE DOE NO. 4, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN 
Defendant. 
JANE DOE NO. 5, 
Plaintiff, 
Vs. 
JEFFREY EPSTEIN, 
Defendant. 
CASE NO.: 08-CV-80119-MARRA/JOHNSON 
CASE NO.: 08-CV-80232-MARRA/JOHNSON 
CASE NO.: 08-CV-80380-MARRA/JOHNSON 
CASE NO.: 08-CV-8038I-MARRA/JOHNSON 
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Doe 101 v. Epstein 
Page 2 
CASE NO.: 08-80994.CIV-MARRA/JOHNSON 
JANE DOE NO. 6, 
Plaintiff, 
JEFFREY EPSTEIN, 
Defendant. 
CASE NO.: 08.80993-CIV-MARRA/JOHNSON 
JANE DOE NO. 7, 
Plaintiff, 
JBM-/REY EPSTEIN 
Defendant. 
CASE NO.: 08-80811-CIV-MARRA/JOHNSON 
Plaintiff, 
JEFFREY EPSTEIN 
Defendant. 
JANE DOE, 
CASE NO.: 08-80893-CIV-MARRA/JOHNSON 
Plaintiff, 
JEFFREY EPSTEIN et al, 
Defendants. 
DOE II, 
CASE NO.: 09-80469-CIV-MARRA-JOHNSON 
Plaintiff, 
JEFFREY EPSTEIN et al, 
Defendants. 
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• Case 9:08-cv-80119-KAM 
Document 151 
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Doe 101 v. Epstein 
Page 3 
JANE DOE NO. 101, 
Plaintiff, 
JEFFREY EPSTEIN 
Defendant. 
JANE DOE NO. 102, 
Plaintiff, 
JEFFREY EPSTEIN, 
Defendant. 
CASE NO.: 09-80591-CIV-MARRA-JOHNSON 
CASE NO.: 09-80656-CIV-MARRA/JOHNSON 
DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 
101 and 102's MOTION FOR AN ORDER FOR THE PRESERVATION OF 
EVIDENCE & INCORPORATED MEMORANDUM OF LAW (dated 5/26/09, DE 114) 
Defendant, JEFFREY EPSTEIN, 
("EPSTEIN"), by and through his undersigned 
attorneys responds to the Plaintiffs' Jane Doe No. 101 and Jane Doe No. 102 ("Plaintiffs") 
Motion For And Order For The Preservation Of Evidence And Incorporated Memorandum Of 
Law, [DE 114], and states: 
1. 
Plaintiffs once again mislead and mischaracterize the criminal counts to which 
EPSTEIN pled guilty. Contrary to Plaintiffs' representations in 111 of their motion and in their 
memorandum of law, EPSTEIN pled guilty to one count of felony solicitation (which was not 
related to a minor), under §796.07(2)(f), Fla.Stat., and one count of procuring a minor for 
prostitution under §796.03, Fla. Stat. Plaintiffs' reference to the "pleas of 'guilty' ... to various 
Florida state crimes involving the solicitation of minors for the prostitution and procurement of 
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Doe 101 v. Epstein 
Page 4 
minors for the purposes of prostitution" mischaracterizes the specific counts to which EPSTEIN 
pled guilty. 
2. 
As to Plaintiffs' allegations in 11 2 and 3, many of the Plaintiffs' allegations are 
without any factual basis and know such assertions to be false and untrue. 
3. 
Defendant agrees with Plaintiff's assertion that the Palm Beach Police 
Department (PBPD) executed a search warrant at EPSTEIN's Palm Beach mansion on October 
25, 2005. See 14 Plaintiffs' motion. 
4. 
Defendant's attorneys have no objection to an order to preserve evidence similar 
to the one entered in the case of Doe v. Epstein, et al, Case No. 08-80804-CIV-
MARRA/JOHNSON, (DE 20], and attached hereto as Exhibit A. EPSTEIN's attorneys are 
unaware of any items referenced in Plaintiffs' motion, ¶5-6, having been returned to EPSTEIN or 
his attorneys, but will agree to a preservation of such items to the extent such items exist. 
5. 
As to 17 of Plaintiffs' motion, EPSTEIN and his attorneys have no objection to 
the referenced authorities, (PBPD, FBI, USAO, and PBSAO), preserving items to the extent such 
items even exist, in a manner that said authorities deem appropriate. 
6. 
As to ¶q8, 9, and 10 of Plaintiffs' motion re: documents, Defendant has asserted 
in other matters and asserts here, specific legal objections as well as his U.S. constitutional 
privileges, as follows: My attorneys have counseled me that at the present time I cannot select, 
authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal 
constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the 
United States Constitution. Drawing an adverse inference under these circumstances would 
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Doe 101 v. Epstein 
Page 5 
unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and 
would therefore violate the Constitution. In addition to and without waiving his constitutional 
privileges, the information sought is privileged and confidential, and inadmissible pursuant to the 
terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and §90.410, 
Fla. Stat. Further Defendants objects as the request to preserve evidence is overly broad and 
includes information that is neither relevant to the subject matter of the pending action nor does 
it appear to be reasonably calculated to lead to the discovery of admissible evidence. 
7. 
Responding to the grossly overly broad list and categories of documents and items 
alleged in Plaintiff's motion (j8-10) involves a testimonial component. The Fifth Amendment 
Privilege extends to the act of production where, as here, it involves a self-incriminating 
testimonial communication or "a compelled testimonial aspect." United States v, Hubbell, 530 
U.S. 27, 120 S.Ct. 2037 (2000)• Fisher v. United States, 425 U.S. 391 (1976); McCormick on 
Evidence, Title 6, Chap. 13. The Privilege Against Self-Incrimination, §138 (6th Ed.). See also 
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 - "Mt 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.")• Hoffman v. U.S., 71 S.Ct. 814, 818 (1951), and progeny). 
The Fifth Amendment Privilege may be invoked in a civil action where a litigant or 
witness is being asked to provide information or respond to a question that may incriminate him 
in a crime. See generally, DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4h DCA 
1983). The privilege against self-incrimination may be asserted during discovery when a litigant 
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Doe 101 v. Epstein 
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has "reasonable grounds to believe that the response would furnish a link in the chain of 
evidence needed to prove a crime against a litigant." A witness, including a civil defendant, is 
entitled to invoke the Fifth Amendment privilege whenever there is a realistic possibility that the 
answer to a question could be used in anyway to convict the witness of a crime or could aid in 
the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company 
v. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983). 
The United States Supreme Court has made clear that the scope of the Fifth Amendment 
Privilege includes the circumstances as here "the act of producing documents in response to a 
subpoena (or production request) has a compelled testimonial aspect." United States v, Hubbell, 
530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000). In explaining the application of the privilege, the 
Supreme Court stated: 
We have held that "the act of production" itself may implicitly communicate 
"statements of fact." By "producing documents in compliance with a subpoena, the 
witness would admit that the papers existed, were in his possession or control, and 
were authentic."all2 
Moreover, as was true in this case, when the custodian of 
documents responds to a subpoena, he may be compelled to take the witness stand and 
answer questions designed to determine whether he has produced everything 
demanded by the subpoena. al2g The answers to those questions, as well as the act of 
production itself, may certainly communicate information about the existence, 
custody, and authenticity of the documents. 
Whether the constitutional privilege 
protects the answers to such questions, or protects the act of production itself, is a 
question that is distinct from the question whether the unprotected contents of the 
documents themselves are incriminating. 
FN19. "The issue presented in those cases was whether the act of producing 
subpoenaed documents, not itself the making of a statement, might nonetheless 
have some protected testimonial aspects. The Court concluded that the act of 
production could constitute protected testimonial communication because it might 
entail implicit statements of fact: by producing documents in compliance with a 
subpoena, the witness would admit that the papers existed, were in his possession 
or control, and were authentic. United States v. Doe. 465 U.S.. at 613. and n. 11, 
104 S.Ct. 1237., Fisher, 425 U.S.. at 409-410. 96 S.Ct. 1569., id. at 428. 432. 96 
S.Ct. 1569 (concurring opinions). See Braswell v. United States. 1487 U.S.,1 at 
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Doe 101 v. Epstein 
Page 7 
104 108 S.Ct. 2284, J. id.1 at 122, 108 S.Q. 2284 (dissenting opinion). Thus, the 
Court made clear that the Fifth Amendment privilege against self-incrimination 
applies to acts that imply assertions of fact."... An examination of the Court's 
application of these principles in other cases indicates the Court's recognition that, 
in order to be testimonial, an accused's communication must itself, explicitly or 
implicitly, relate a factual assertion or disclose information. Only then is a person 
compelled to be a 'witness' against himself." Poe v. United States. 487 U.S., at 
209-210, 108 S.Ct. 2341. (footnote omitted). 
FN20. See App. 62-70. Thus, for example, after respondent had been duly sworn 
by the grand jury foreman, the prosecutor called his attention to paragraph A of 
the Subpoena Rider (reproduced in the Appendix, infra, at 2048-2049) and asked 
whether he had produced "all those documents." App. 65. 
Finally, the phrase "in any criminal case" in the text of the Fifth Amendment might 
have been read to limit its coverage to compelled testimony that is used against the 
defendant in the trial itself. It has, however, long been settled that its protection 
encompasses compelled statements that lead to the discovery of incriminating 
evidence even though the statements themselves are not incriminating and are not 
introduced into evidence. Thus, a half century ago we held that a trial judge had 
erroneously rejected a defendant's claim of privilege on the ground that his answer to 
the pending question would not itself constitute evidence of the charged offense. As 
we explained: 
"The privilege afforded not only extends to answers that would in themselves 
support a conviction under a federal criminal statute but likewise embraces those 
which would furnish a link in the chain of evidence needed to prosecute the claimant 
for a federal crime." Hoffman v. United States. 341 U.S. 479, 486, 71 S.Ct. 814, 95 
L.Ed. 1118 (1951). 
Compelled testimony that communicates information that may "lead to 
incriminating evidence" is privileged even if the information itself is not inculpatory. 
Doe v. United States, 487 U.S. 201, 208, n. 6. 108 5.O, 2341, 101 L.Ed.2d 184 
(1988). 
It's the Fifth Amendment's protection against the prosecutor's use of 
incriminating information derived directly or indirectly from the compelled testimony 
of the respondent that is of primary relevance in this case. 
In summarizing its holding regarding the application of the Fifth Amendment Privilege to 
a production request, the Hubbell Court left "no doubt that the constitutional privilege against 
self incrimination protects" not only "the target of a grand jury investigation from being 
compelled to answer questions designed to elicit information about the existence of sources of 
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Doe 101 v. Epstein 
Page 8 
potentially incriminating evidence," but the privilege also "has the same application to the 
testimonial aspect of a response to a subpoena seeking discovery of those sources." At 43, and 
2047. Here, Plaintiffs' motion to preserve evidence by listing a large inventory of items is in 
reality no different that propounding a discovery request upon Defendant, and thus, Defendant is 
afforded the protection of the Constitutional privileges asserted herein. 
8. 
As stated above, Defendant and Defendant's attorneys have no objection to the 
entry of an order similar to Exhibit A hereto. 
WHEREFORE, Defendant requests that the Court enter an order similar to that as entered 
in Exhibit A hereto. 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the 
Clerk of the Court using CMJECF. 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 
CMIECF on this tday of  June  , 2009 
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'Case 9:08-cv-80119-KAM 
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Doe 101 v. Epstein 
Page 9 
Respectful! 
By: 
ROBERT D. R1TTON, JR., ESQ. 
Florida Bar o. 224162 
ESQ. 
Florida Bar #617296 
BUI
1E,N1, 
LUTHER & COLEMAN 
515 N. Hagler Drive, Suite 400 
West Palm Beach, FL 33401 
Phone 
Fax 
(Course or D efendant Jeffrey Epstein) 
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Case 9:08-cv-80119-KAM 
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Doe 101 v. Epstein 
Page 10 
Certificate of Service 
Jane Doe No. 2 v. Jeffrey Epstein 
Case No. 08-CV-80119-MARRA/JOHNSON 
Stuart S. Mermelstein, Esq. 
Adam D. Horowitz, Esq. 
Mermelstein & Horowitz, P.A. 
18205 Biscayne Boulevard 
Suite 2218 
Miami 
160 
Fax: 
Counsel for Plaintiffs in Related Cases Nos. 
08-80069, 08-80119, 08-80232, 08-80380, 08-
80381, 08-80993, 08-80994 
Richard Horace Willits, Esq. 
Richard H. Willits, P.A. 
2290 10th Avenue North 
Suite 404 
33461 
Fax: 
Counsel for Plaintiff in Related Case No. 08-
80811 
Jack Scarola, Esq. 
Jack P. Hill, Esq. 
Searcy Denney Scarola Barnhart & Shipley, 
P.A. 
2139 Palm Beach Lakes Boulevard 
ach, FL 33409 
Counsel for Plaintiff, 
Brad Edwards, Esq. 
Rothstein Rosenfeldt Adler 
401 East Las Olas Boulevard 
Suite 1650 
Fort 
3301 
Phon 
Fax: 
Counsel for Plaintiff in Related Case No. 08-
80893 
Paul G. Cassell, Esq. 
Pro Rae Vice 
332 South 1400 E, Room 101 
Salt IBke City, LIT 84112 
Co-counsel for Plaintiff Jane Doe 
Isidro M. Garcia, Esq. 
Garcia Law Firm, P.A. 
224 Datura Street, Suite 900 
Reach, FL 33401 
Counsel for Plaintiff in Related Case No. 08-
80469 
Roberti. Josefsberg, Esq. 
Katherine W. Ezell, Esq. 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
130 
Fax: 
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Doe 101 v. Epstein 
Page 11 
Bruce Reinhart, Esq. 
Bruce E. Reinhart, P.A. 
250 S. Australian Avenue 
Suite 1400 
West Palm Beach, FL 33401 
•
 
Counsel for Defendant 
Theodore J. Leopold, Esq. 
Spencer T. Kuvin, Esq. 
Ricci-Leopold, P.A. 
2925 PGA Blvd., Suite 200 
Palm Beach Gardens, FL 33410 
Fax: 
Counsel for Plaintiff in Related Case No. 08-
t i t ais
Counsel for Plaintiffs in Related Cases Nos. 
09-80591 and 09-80656 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
ach, FL 33401-5012 
Counsel for Defendant Jeffrey Epstein 
EFTA00175469