EFTA00175214

CM/ECF Live Database - flsd 
Page 9 of 16 
04/02/2009) 
04/09/2009 
- 
55 
r 
41.8 
KB
Plaintiffs MOTION for Extension of Time to File Response as to 51 
Defendant's MOTION to Stay re 40 Amended Complaint and or Continue 
Action by 
. (Hill, Jack) (Entered: 04/09/2009) 
04/10/2009 
56 
ENDORSED ORDER granting 55 Motion for Extension of Time to 
Respond re 51 Defendant's MOTION to Stay re 40 Amended Complaint 
and or Continue Action. Responses due by 4/24/2009. Signed by Judge 
Kenneth A. Mara on 4/10/2009. (ir) (Entered: 04/10/2009) 
04/13/2009 
57 
r 
3682
Ica 
NOTICE of Mediator Selection: Mark Buckstein selected.(Hill, Jack) 
(Entered: 04/13/2009) 
04/13/2009 
58 r
1.8 
M f3
RESPONSE to Motion re 47 Defendant's MOTION to Dismiss 40 
Amended Complaint (First) filed by 
. Replies due by 4/23/2009. 
(Hill, Jack) (Entered: 04/13/2009) 
04/14/2009 
59 
r 
2°61
ka 
NOTICE by 
of Filing Correction to Page Four of Plaintif 's 
Memorandum o Law in Response to Defendant, Jeffrey Epstein's Motion 
to Dismiss First Amended Complaint for Failure to State a Cause of 
Action, and Motion for More Definite Statement; Motion to Strike, and 
Supporting Memorandum of Law filed on April 13, 2009 (Hill, Jack) 
(Entered: 04/14/2009) 
04/17/2009 
60 
r
158.6 
KB
Defendant's MOTION for Extension of Time to File Reply as to 58 
Response to Motion by Jeffrey Epstein. (Pike, Michael) (Entered: 
04/17/2009) 
04/20/2009 
61 
ENDORSED ORDER granting 60 Motion for Extension of Time to Reply 
re 47 Defendant's MOTION to Dismiss 4(1 Amended Complaint (First). 
Replies due by 5/8/2009. Signed by Judge Kenneth A. Marra on 
4/20/2009. (ir) (Entered: 04/20/2009) 
04/20/2009 
62 
r
1.2 
MB
RESPONSE in Opposition re 54 Defendant's MOTION to Compel 
Response to 1st RTP and 1st Interrogs filed by 
. (Hill, Jack) 
(Entered: 04/20/2009) 
04 /22%2009 
63 
r 
313:: 
MOTION for Leave to File Jane Doe's No. 101's Motion For Leave to 
File Brief as Amicus Curiae in Support of Plaintiffs Response in 
Opposition to Defendant Jeffrey Epstein's Motion to Dismiss and 
Certification of Having Conferred Pursuant to S.D.Fla.L.R. 7.1.A.3 by 
Jane Doe No. 101. (Attachments: # 1 Text of Proposed Order)(Josefsberg, 
Robert) (Entered: 04/22/2009) 
04/24/2009 
M 
17
Ma 
RESPONSE in Opposition re 51 Defendant's MOTION to Stay re 40 
Amended Complaint and or Continue Action filed by 
.. 
(Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Hill, Jack) 
ntered: 
04/24/2009) 
httos://eef,f1sd.uscourts.gov/cgi bin/DktRpt.p179135369616841682-L 801_0-1 
6/10/2009 
EFTA00175334

CM/ECF Live Database - flsd 
Page 10 of 16 
04./27/2009 
65 r
189.2 
KB 
Defendant's MOTION for Leave to File Excess Pages in his Reply to 
Plaintiff's Memo in Response to Motion to Dismiss by Jeffrey Epstein. 
(Pike, Michael) (Entered: 04/27/2009) 
04/27/2009 
66 
ENDORSED ORDER granting 65 Motion for Leave to File Excess Pages. 
Reply may exceed 10 pages. Signed by Judge Kenneth A. Marra on 
4/27/2009. (ir) (Entered: 04/27/2009) 
04/28/2009 
68 r
602 
KB
ORDER TO SHOW CAUSE why cases should not be consolidated for 
discovery purposes Show Cause Response due by 5/5/2009.. Signed by 
Judge Kenneth A. Marra on 4/28/2009. (cqs) (Entered: 04/29/2009) 
04/29/2009 
61 
r
1.2 
MB
Defendant's MOTION to Compel and/or 'den* el 
in the Style of 
This Case and Motion to 'den* II 
in Third arty Subpoenas for 
Purposes of Discovery, or Alternative y, Motion to Dismiss Sua Sponte , 
with Incorporated Memorandum of Law by Jeffrey Epstein. Responses 
due by 5/18/2009 (Attachments: # I Motion to Compel and or Identify, # 
2 Motion to Compel and or IdentifyXPike, Michael) (Entered: 
04/29/2009) 
04/29/2009 
-
69 r
150.3 
KB
Defendant's MOTION for Extension of Time to File Reply to Plaintiff's 
Memorandum in Opposition to Defendant, Jeffrey Epstein's Motion to 
Stay and or Continue Action for Time Certain Based on Parallel Civil and 
Criminal Proceedings by Jeffrey Epstein. (Pike, Michael) (Entered: 
04/29/2009) 
04/30/2009 
70 
r i
1.3 
MB 
REPLY to Response to Motion re 54 Defendant's MOTION to Compel 
Response to 1st RTP and 1st Interrogs , and to Overrule Objections, and 
for an Award of Defendant's Reasonable Expenses filed by Jeffrey 
Epstein. (Attachments: # 1 Exhibit A to Defendant Epstein's Reply to 
Response in Opposition to Motion to Compel, # 2 Exhibit A-1 to Def. 
Epstein's ReplyXPike, Michael) (Entered: 04/30/2009) 
05/04/2009 
71 
ENDORSED ORDER granting 69 Motion for Extension of Time to Reply 
re 5_1 Defendant's MOTION to Stay re 0 Amended Complaint and or 
Continue Action. Replies due by 5/11/2009. Signed by Judge Kenneth A. 
Marra on 5/4/2009. (ir) (Entered: 05/04/2009) 
05/04/2009 
72 
- 
r 
265.1
ics 
RESPONSE TO ORDER TO SHOW CAUSE by 
.. (Hill, Jack) 
(Entered: 05/04/2009) 
05/04/2009 
73 
11 
278.6
ic
MEMORANDUM in Opposition re 68 Order to Show Cause by Jeffrey 
Epstein. (Pike, Michael) (Entered: 05/04/2009) 
05/04/2009 
74 
MOTION for clarification 68 Order to Show Cause by Jeffrey Epstein. 
Responses due by 5/21/2009. See image DE 73 (1k) Modified link on 
5/5/2009 (lk). (Entered: 05/05/2009) 
05/05/2009 
75 
Clerks Notice of Docket Correction and Instruction to Filer re 73 
https://ecf.flsd.uscourts.gov/cgi-bitt/DktRpt.p1T985369616841682-L_801_0-1 
6/10/2009 
EFTA00175335

ClvVECF 7 Live Database - flsd 
Page 11 of 16 
Memorandum in Opposition filed by Jeffrey Epstein. Error - Two or 
More Document Events Filed as One; Correction - Additional event(s) 
74 MOTION FOR CLARIFICATION docketed by Clerk. Instruction to 
Filer - In the future, please select all applicable events, UNDER 
MOTIONS. It is not necessary to refile this document. (1k) (Entered: 
05/05/2009) 
05/05/2009 
76 r
145.3 
KB 
Defendant's MOTION for Extension of Time to File Reply as to 64 
Response in Opposition to Motion by Jeffrey Epstein. (Critton, Robert) 
(Entered: 05/05/2009) 
05/06/2009 
77 
ENDORSED ORDER granting 76 Motion for Extension of Time to Reply 
re 51 Defendant's MOTION to Stay re 4() Amended Complaint and or 
Continue Action. Replies due by 5/15/2009. Signed by Judge Kenneth A. 
Marra on 5/5/2009. (ir) (Entered: 05/06/2009) 
05/08/2009 
78 
r
Ls 
Is4B 
REPLY to Response to Motion re 47 Defendant's MOTION to Dismiss 40 
Amended Complaint (First) filed by Jeffrey Epstein. (Critton, Robert) 
(Entered: 05/08/2009) 
05/08/2009 
:79 
r 
18M 
KB
Defendant's MOTION for Extension of Time to File Response as to 63 
MOTION for Leave to File Jane Doe's No. 101's Motion For Leave to 
File Brief as Amicus Curiae in Support of Plaintiffs Response in 
Opposition to Defendant Jeffrey Epstein's Motion to Dismiss and 
Certification of Having Conferre by Jeffrey Epstein. (Pike, Michael) 
(Entered: 05/08/2009) 
05/11/2009 
- 
80 
ENDORSED ORDER granting 79 Motion for Extension of Time to 
Respond re 63 MOTION for Leave to File Jane Doe's No. 101's Motion 
For Leave to File Brief as Amicus Curiae in Support of Plaintiffs 
Response in Opposition to Defendant Jeffrey Epstein's Motion to Dismiss 
and Certification of Having Conferre.. Responses due by 5/15/2009. 
Signed by Judge Kenneth A. Marra on 5/11/2009. (ir) (Entered: 
05/11/2009) 
05/13/2009 
81 
r
383.3 
KB 
RESPONSE/REPLY to 64 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 
82 
r Iv 
ORDER CONSOLIDATING CASES. Hereinafter all motions and other 
court filings that relate to discovery and all procedural motions that relate 
to multiple cases shall be styled with all of the case names and numbers 
and shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge 
Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-ICAM 
et al. (ir) (Entered: 05/14/2009) 
05/14/2009 
83 
ORDER REQUESTING UNITED STATES PROVIDE POSITION TO 
httos://eef.flsd.uscourts.gov/egi bin/DktRptpl?985369616841682-L 801_0-1 
6/10/2009 
EFTA00175336

CM/ECF - Live Database - flsd 
Page 12 of 16 
. . 
• 
r
1.3 
MB
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. (ir) (Entered: 05/14/2009) 
05/14/2009 
84 
ORDER denying as moot 74 Motion for Clarification. See Order 
consolidating cases.. Signed by Judge Kenneth A. Marra on 5/14/2009. 
(Ic3) (Entered: 05/14/2009) 
05/14/2009 
85 
ORDER terminating 51 Motion to Stay; terminating 67 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 
5/14/2009. (1c3) (Entered: 05/14/2009) 
05/15/2009 
86 
r 
MB
Plaintiffs MOTION for Extension of Time to File Response to 
Defendant's Motion to Ident( a 
in Third-Party Subpoenas for 
Purposes of Discovery, or Alternatively, Motion to Dismiss Sua Sponte, 
With Incorporated Memorandum of Law by 
. Associated Cases: 
9:08-cv-80119-KAM, 9:08-cv-80811-KAM 
ack) (Entered: 
05/15/2009) 
05/15/2009 
87 
ri
357.7 
KB
RESPONSE in Opposition re 63 MOTION for Leave to File Jane Doe's 
No. 101's Motion For Leave to File Brief as Amicus Curiae in Support of 
Plaintiffs Response in Opposition to Defendant Jeffiey Epstein's Motion 
to Dismiss and Certification of Having Conferre filed by Jeffrey Epstein. 
(Pike, Michael) (Entered: 05/15/2009) 
05/18/2009 
88 
ORDER terminating 86 Motion for Extension of Time to Respond. Filing 
motion in 08-80119 is sufficient, as the underlying motion to compel 
identity is pending in 08-80119 for all the cases.. Signed by Judge 
Kenneth A. Marra on 5/18/2009. (1c3) (Entered: 05/18/2009) 
05/18/2009 
89 
r, 
0.6 
NIB 
Plaintiff's MOTION to Strike Ik e ly to Response to Motion to Dismiss 
First Amended Complaint by 
. Responses due by 6/5/2009 (Hill, 
Jack) (Entered: 05/18/2009) 
05/19/2009 
2Q 
r 
a 
Defendant's MOTION to Strike Cases from Current Trial Docket by 
Jeffrey Epstein. Responses due by 6/8/2009 (Attachments: # I Exhibit A) 
Associated Cases: 9:08-cv-80119-KAM et al.(Pike, Michael) (Entered: 
05/19/2009) 
05/19/2009 
91
r
56.7 
KB
MOTION for Leave to Withdraw as Co-Counsel by Jeffrey Epstein. 
(Attachments: # 1 Text of Proposed OrderXTein, Michael) Event 
Modified on 5/20/2009 (ail). (Entered: 05/19/2009) 
05/20/2009 
92 
ORDER terminating (93) Motion to Strike ; terminating (94) Motion in 
case 9:08-cv-80232-ICAM; 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-
httos://eciflsd.useourts.gov/cgi-bin/DktRpt.p17985369616841682-L_801_0-1 
6/10/2009 
EFTA00175337

CM/ECF Live Database - flsd 
Page 13 of 16 
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-KAM. Signed by 
Judge Kenneth A. Marra on 5/20/2009. (1c3) (Entered: 05/20/2009) 
05/20/2009 
93 
r 
363.1 
KB
NOTICE by 
of Filing Withdrawal of Previously Raised 
Objections to e endant, Jetty Epstein's Motion to Compel And/Or 
Identify 
in the Style of This Case and Motion to Identify 
in 
Third-Party ubpoenas for Purposes of Discovery, Or, Alternative y, 
Motion to Dismiss Sua Sponte, With Inorporated Memorandum of Law 
Associated Cases: 9:08-cv-80119-ICAM et al.(Hill, Jack) (Entered: 
05/20/2009) 
05/20/2009 
94 
- 
ll 
li9cli3
RESPONSE in Opposition re 89 Plaintiffs MOTION to Strike 21_3  Reply to 
Response to Motion to Dismiss First Amended Complaint for Failure to 
State a Cause of Action filed by Jeffrey Epstein. (Critton, Robert) 
(Entered: 05/20/2009) 
05/20/2009 
95 
Clerks Notice of Docket Correction and Instruction to Filer re 91 
MOTION Motion for Leave to Withdraw as Co-Counsel filed by Jeffrey 
Epstein. The Filer selected the wrong motion relief when docketing the 
Motion. The correction was made by the Clerk. It is not necessary to refile 
this document but future motions filed must include all applicable relief 
events. (ail) (Entered: 05/20/2009) 
05/20/2009 
96 
ORDER STRIKING in all Epstein cases EXCEPT case no. 08-80119: 
Notice by 
of Filing Withdrawal of Previously Raised Objections 
to Epstein'inn 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 
97 r
361.9 
KB 
RESPONSE/REPLY Jane Doe No. 101's Reply to Defendant's Response 
in Opposition to Jane Doe No. 101's Motion for Leave to File Brief as 
Amicus Curiae in Support of Plaintiffs Reponse In Opposition to 
Defendant Jay Epstein's Motion to Dismiss by Jane Doe No. 101. 
(Ezell, Katherine) (Entered: 05/21/2009) 
05/21/2009 
98 
2r
.2 
0 
KB 
RESPONSE/REPLY to 89 Plaintiffs MOTION to Strike Z8 Reply to 
Response to Motion to Dismiss First Amended Complaint Plaintiffs Jane 
Doe No. 101 and Jane Doe No. 102's Response in Support of Plaintiff 
is Motion to File Surreply to Defendant's Reply to Plaintiff's 
Memorandum in Response to Defendant's Motion to Dismiss First 
Amended Complaint For Failure to State a Cause of Action and Motion 
for More Definite Statement by Jane Doe No. 101. (Ezell, Katherine) 
(Entered: 05/21/2009) 
05/27/2009 
99 
NOTICE by Jane Doe re (111 in 9:08-cv-80119-KAM) Plaintiffs 
httns://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?985369616841682-L_801_0-1 
6/10/200) 
EFTA00175338

CM/ECF 7 Live Database - flsd 
Page 14 of 16 
. , 
11
5:: 
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: # 1 Text of Proposed Order)Associated Cases: 9:08-cv-
80119-KAM et al.(Horowitz, Adam) (Entered: 05/27/2009) 
05/28/2009 
100 
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. Main on 5/28/2009. 
Associated Cases: 9:08-cv-80119-KAM et al. (Ic3) (Entered: 05/28/2009) 
05/28/2009 
I 0 I 
i
so i 
KB
ORDER denying 63 Motion for Leave to File Brief; denying 89 Motion to 
Strike. Signed by Judge Kenneth A. Marra on 5/28/2009. (ir) (Entered: 
05/28/2009) 
05/29/2009 
102 
n 
11 6 
KR 
NOTICE of Attorney Appearance by 
I. 
on behalf of 
afiraaf
ica Associated Cases: 9:08-cv-80119-KAM et al. 
r 
MEW 
(Entered: 05/29/2009) 
05/29/2009 
103 
r 
3;iii
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. 
lie 
09. Associated Cases: 9:08-cv-80119-KAM et al. 
MEM) (Entered: 05/29/2009) 
05/29/2009 
104 
r
223.6 
KB
Defendant's MOTION to Strike 98 Response/Reply (Other), 
Response/Reply (Other), Response/Reply (Other) by Jeffrey Epstein. 
Responses due by 6/15/2009 (Pike, Michael) (Entered: 05/29/2009) 
05/29/2009 
105 
r 
43.3 
KB
RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's 
MOTION to Compel Identify Doe in Style of Case and in Third-Party 
Subpoenas, (91 in 9:08-cv-80119-KAM) Defendant's MOTION to 
Compel Identity of Doe in Style of Case and Third-Party Subpoenas 
(replaces Docket entry 90) filed by Jane Doe No. 102, Jane Doe No. 101. 
Associated Cases: 9:08-cv-80119-KAM et al.(Ezell, Katherine) (Entered: 
05/29/2009) 
https://ed.flsd.useourts.gov/cgi-bin/DktRpt.p1T985369616841682-L_801_0-1 
6/10/2009 
EFTA00175339

CM/ECF: Live Database - flsd 
Page 15 of 16 
05/29/2609 
106 
ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in 
9:08-cv-80232-ICAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-
KAM, 25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-ICAM, 22 in 9:09-
cv-80656-KAM, 107 in 9:08-cv-80381-ICAM) Response in Opposition to 
Motion, filed by Jane Doe No. 102, Jane Doe No. 101 DO NOT FILE IN 
EVERY EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES.. 
Signed by Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-
cv-80119-KAM et al. (1c3) (Entered: 05/29/2009) 
05/29/2009 
107 
r 
24.5 
KB
MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION 
TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, TO 
UNSEAL THE NONPROSECUTION AGREEMENT by Jane Doe No. 102, 
Jane Doe No. 101. Associated Cases: 9:08-cv-80119-KAM et al.(Ezell, 
Katherine) (Entered: 05/29/2009) 
05/29/2009 
108 
r
19.5 
KB
MOTION for Hearing MOTION TO RESCHEDULE HEARING by Jane 
Doe No. 102, Jane Doe No. 101. Associated Cases: 9:08-cv-80119-KAM 
et al.(Josefsberg, Robert) (Entered: 05/29/2009) 
06/01/2009 
109 
ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
KAM, 109 in 9:08-cv-80232-ICAM, 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-KAM, 109 in 9:08-cv-
80381-KAM, 108 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-ICAM, 
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) 
06/01/2009 
110 
ENDORSED ORDER denying as moot 104 Motion to Strike. See DE 101 
denying motion to strike or to file sur-reply. Signed by Judge Kenneth A. 
Marra on 5/29/2009. (ir) (Entered: 06/01/2009) 
06/04/2009 
111 
r 
349.0 
KB
REPLY to Response to Motion re (113 in 9:08-cv-80119-ICAM) Plaintiff's 
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 Plaint* 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 
1 12 
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 
https://ecf.flsd.uscourts.gov/cgi bin/DktRpt.pl?985369616841682-L_801_0-1 
6/10/2009 
EFTA00175340

CM/ECF - Live Database - flsd 
Page 16 of 16 
' • . 
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-ICAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09-
cv-80469-ICAM, 79 in 9:08-cv-80993-KAM) Reply to Response to 
Motion, filed by Jane Doe No. 102, Jane Doe No. 101 Document stricken 
for failure to follow Court's orders. DO NOT FILE A DOCUMENT IN 
EVERY EPSTEIN CASE if it is to be filed only in 08-80119. See Case 
Management Order and contact CM/ECF Support for assistance in proper 
filing.. Signed by Judge Kenneth A. Marra on 6/4/2009. Associated Cases: 
9:08-cv-80119-ICAM et al. (1c3) (Entered: 06/04/2009) 
06/05/2009 
113 
r
295.8 
KB 
NOTICE by 
of Filing Conditional Notice of Intent to Exclusively 
Rely on Statutory Damages Provided by 18 US.C. 2255 (Hill, Jack) 
(Entered: 06/05/2009) 
06/05/2009 
114 
r
0.6 
MB
Plaintiff's MOTION for Protective Order Regarding Treatment Records 
From Parent-Child Centgrajugh and Dr. Serge Thys and Incorporated 
Memorandum of Law by
.. (Hill, Jack) (Entered: 06/05/2009) 
06/08/2009 
115 
r
3.8 
MB 
RESPONSE to Motion re (91 in 9:08-cv-80119-KAM) Defendant's 
MOTION to Compel Identity of Doe in Style of Case and Third-Party 
Subpoenas (replaces Docket entry 90) filed by Jane Doe. Replies due by 
6/18/2009. (Attachments: # 1 Exhibit A, # 2 Exhibit B)Associated Cases: 
9:08-cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/08/2009 
116 
p 
106.1 
KB 
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-ICAM et al.(Horowitz, Adam) (Entered: 
06/08/2009) 
View Selected 
Total filesize of selected documents (MB): I 
or 
Maximum filesize allowed (MB): 10 
Download Selected 
PACER Service Center 
Transaction Receipt 
06/10/2009 13:34:47 
PACER 
Login: 
du4480 
Client Code: 
Description: 
Docket 
Report 
Search 
Criteria: 
9:08-ev-80811- 
M 
Billable 
Pages: 
10 
Cost: 
0.80 
https://ecf.flsd.uscourts.gov/egi-bin/DktRpt.p17985369616841682-L_801_0-1 
6/10/2009 
EFTA00175341

Case 9:08-cv-80811-KAM 
Document 47 
Entered on FLSD Docket 03/12/2009 
Page 1 of 21 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80811-MARRA/JOHNSON 
In A., 
Plaintiff, 
v. 
US 
EPSTEIN and 
Defendants, 
DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS FIRST 
AMENDED COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION, 
AND MOTION FOR MORE DEFINITE STATEMENT; MOTION TO STRIKE, 
AND SUPPORTING MEMORANDUM OF LAW 
Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned 
counsel, moves to dismiss Count I through XXXI of Plaintiff's First Amended Complaint 
for failure to state a cause of action, and for more definite statement, or to strike, as 
specified herein. Rule 12(b)(6), (e) and (f), Fed.R.Civ.P. (2008); Local Gen. Rule 7.1 
(S.D. Fla. 2008). In support of dismissal, Defendant states: 
The First Amended Complaint attempts to allege 32 counts. Counts I through 
XXX are purportedly brought pursuant to 18 U.S.C. §2255 - Civil Remedies for 
Personal Injuries; Count XXXI is entitled "Sexual Battery," and Count XXXII is entitled 
"Conspiracy to Commit Tortious Assault only against Defendant, 
." Under 
the heading "Factual Allegations" of the First Amended Complaint, Plaintiff also 
references numerous federal and state criminal statutes, but fails to allege whether or 
not she is attempting to assert claims based on these statutes. (¶15, 1st Am. Comp.). 
EFTA00175342

Case 9:08-cv-80811-KAM 
Document 47 
Entered on FLSD Docket 03/12/2009 
Page 3 of 21 
M
. v. Epstein, et al. 
Page 3 
assumption that all the allegations in the complaint are true (even if doubtful in fact)." Id. 
On a motion to dismiss, the well pleaded allegations of plaintiffs complaint are taken as 
true and construed in the light most favorable to the plaintiff. M.T.V. v. DeKalb County 
Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006). 
Significantly, the Supreme Court in Bell Atlantic Corp. V. Twombly abrogated the 
often cited observation that "a complaint should not be dismissed for failure to state a 
claim unless it appears beyond doubt that the plaintiff can prove no set of facts in 
support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley 
v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme 
Court rejected the notion that "a wholly conclusory statement of claim [can] survive a 
motion to dismiss whenever the pleadings le[ave] open the possibility that a plaintiff 
might later establish some 'set of [undisclosed] facts' to support recovery." Id. As 
explained by the Supreme Court in Bell Atlantic Corp., supra at 1664-65: 
While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not 
need detailed factual allegations ibid.: Sanjuan v. American Bd. of 
Psychiatry and Neurology, Inc., 40 F.3d 247, 251 (C.A.7 1994), a plaintiffs 
obligation to provide the "grounds" of his "entitle[ment] to relief' requires 
more than labels and conclusions, and a formulaic recitation of the elements 
of a cause of action will not do, see Papasan v. Allain, 478 U.S. 265, 286, 
106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are 
not bound to accept as true a legal conclusion couched as a factual 
allegation"). Factual allegations 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) 
("[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 
doubtful in fact), see, e.g., Swierkiewicz v. Sorema N. A., 534 U.S. 506, 508, 
n. 1, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002); Neitzke v. Williams, 490 U.S. 319, 
327, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1989) (" Rule 12(b)(6) does not 
countenance ... dismissals based on a judge's disbelief of a complaint's 
EFTA00175343

Case 9:08-cv-80811-KAM 
Document 47 
Entered on FLSD Docket 03/12/2009 
Page 5 of 21 
M
. v. Epstein, et al. 
Page 5 
Contrary to Plaintiff's attempted assertion of 30 separate counts pursuant to 18 
U.S.C.A. §2255 - Civil Remedy for Personal Injuries, this statute creates a single federal 
cause of action or "civil remedy" for a minor victim of sexual, abuse, molestation and 
exploitation. Under the plain meaning of the statutory text, §2255 does not create 
separate causes of action on behalf of a minor against a defendant on a "per violation" 
basis. No where in the statutory text is there any reference to the civil remedy afforded 
by this statute as being on a "per violation" basis. 18 U.S.C. 2255(a) creates a civil 
remedy for "a minor who is a victim of a violation of section 2241(c), 2242, 2243, 2251, 
2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal 
injury as a result of such violation ... ." See Smith v. Husband 428 F.Supp.2d 432 
(E.D. Va. 2006); Smith v. Husband, 376 F.Supp.2d 603 (E.D. Va. 2006); Doe v. 
Liberatore, 478 F.Supp.2d 742, 754 (M.D. Pa. 2007); and the recent cases in front of 
this court on Defendant's Motions to Dismiss and For More Definite Statement — Doe 
No. 2 v. Epstein 2009 WL 383332 (S.D. Fla. Feb. 12, 2009). Doe No. 3 v. Epstein, 
2009 WL 383330 (S.D. Fla. Feb. 12, 2009); Doe No. 4 v. Epstein, 2009 WL 383286 
(S.D. Fla. Feb. 12, 2009); and Doe No. 5 v. Epstein, 2009 WL 383383 (S.D. Fla. Feb. 
12, 2009). 
There is no reported case supporting Plaintiff's tortured and nonsensical 
interpretation of §2255. In all of these cases (cited above), each of the Plaintiffs brought 
a single count or cause of action attempting to allege numerous violations of the 
"predicate acts" specifically identified in §2255. "18 U.S.C. §2255 gives victims of 
sexual conduct who are minors a private right of action." Martinez v. White 492 
EFTA00175344

Case 9:08-cv-80811-KAM 
Document 47 
Entered on FLSD Docket 03/12/2009 
Page 7 of 21 
v. Epstein, et al. 
age 
v. Husband, 376 F.Supp.2d at 610 ("When interpreting a statute, [a court's] inquiry 
begins with the text."). "The Court must first look to the plain meaning of the words, and 
scrutinize the statute's 'language, structure, and purpose." Id. In addition, in construing 
a statute, a court is to presume that the legislature said what it means and means what 
it said, and not add language or give some absurd or strained interpretation. As stated 
in CBS. Inc supra at 1228 — "Those who ask courts to give effect to perceived 
legislative intent by interpreting statutory language contrary to its plain and 
unambiguous meaning are in effect asking courts to alter that language, and '[c]ourts 
have no authority to alter statutory language.... We cannot add to the terms of Ethel 
provision what Congress left out.' Merritt, 120 F.3d at 1187." See also Dodd v. U.S. 
125 S.Ct. 2478 (2005); 73 Am.Jur.2d Statutes §124. 
Title 18 of the U.S.C.. is entitled "Crimes and Criminal Procedure." §2255 is 
contained in "Part I. Crimes, Chap. 110. Sexual Exploitation and Other Abuse of 
Children." 18 U.S.C. §2255 (2003), is entitled Civil remedy for personal injuries, and 
provides: 
(a) Any minor who is a victim of a violation of section 2241(c), 2242, 2243, 2251, 
2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers 
personal injury as a result of such violation may sue in any appropriate United 
States District Court and shall recover the actual damages such minor sustains 
and the cost of the suit, including a reasonable attorney's fee. Any minor as 
described in the preceding sentence shall be deemed to have sustained 
damages of no less than $50,000 in value. 
(b) Any action commenced under this section shall be barred unless the complaint 
is filed within six years after the right of action first accrues or in the case of a 
person under a legal disability, not later than three years after the disability. 
Reading the entire statute in context, no where is there any language indicating 
that a minor plaintiff has a private right of action against a defendant "per violation." 
EFTA00175345

Case 9:08-cv-80811-KAM 
Document 47 
Entered on FLSD Docket 03/12/2009 
Page 9 of 21 
v. Epstein, et al. 
iage 9 
brought a single cause of action, based on allegations of multiple violations of the §2255 
predicate acts. Furthermore, the court refused to add a venue interpretation that simply 
was not written into the statutory text. See other §2255 cases cited herein. 
For an example of a statute wherein the legislature included the language "for 
each violation" in assessing a "civil penalty," see 18 U.S.C. §216, entitled "Penalties and 
injunctions," of Chapter 11 — "Bribery, Graft, and Conflict of Interests," also contained in 
Title 18 — "Crimes and Criminal Procedure." Subsection (b) of §216 gives the United 
States Attorney General the power to bring a "civil action ... against any person who 
engages in conduct constituting an offense under" specified sections of the bribery, 
graft, and conflicts of interest statutes. The statute further provides in relevant part that 
"upon proof of such conduct by a preponderance of the evidence, such person shall be 
subject to a civil penalty of not more than $50,000 for each violation or the amount of 
compensation which the person received or offered for the prohibited conduct, which 
ever amount is greater." As noted, 18 U.S.C. §2255 does not include such language. 
Accordingly, Plaintiffs multiple counts brought pursuant to §2255 are required to 
be dismissed for failure to state multiple causes of action. 
B. Also requiring dismissal Plaintiff has failed to sufficiently allege 
the requisite 52255 predicate acts. 
Also requiring dismissal of Plaintiffs purported §2255 claim(s) is Plaintiff's failure 
to sufficiently allege any violation of a requisite predicate act as specifically identified in 
subsection (a) of the statute quoted above. Relevant to Plaintiff's complaint, 18 U.S.C. 
2255(a) creates a civil remedy for "a minor who is a victim of a violation of section 
2241(c), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title 
EFTA00175346

Case 9:08-cv-80811-KAM 
Document 47 
Entered on FLSD Docket 03/12/2009 
Page 11 of 21 
. v. Epstein, et al. 
1111 
the standard of pleading as established in Twombly, supra, Plaintiff has failed to 
sufficiently allege the requisite elements of a §2255 claim, thus requiring dismissal; for 
failure to state a cause of action. 
C. 18 U.S.C. 42255 does not allow for the recovery of punitive damages. 
Thus, Plaintiff's request for punitive damages under 42255 is required to be 
dismissed or stricken. 
In each of the improperly asserted Counts I through XXX, Plaintiff also seeks 
punitive damages. 
A plain reading of 18 U.S.C. §2255, quoted above herein, 
establishes that the statute does not allow for the recovery of punitive damages. Had 
Congress wanted to allow for such a recovery, it could have easily written such 
language into the damages provision of the statute. The legislative body chose not to 
write a punitive damages component into §2255 as it has done in other statutes 
affording civil remedies. In relevant part, §2255 reads - Any minor who is a victim of a 
violation of section ... of this title and who suffers personal injury as a result of such 
violation may sue in any appropriate United States District Court and shall recover the 
actual damages such minor sustains and the cost of the suit, including a 
reasonable attorney's fee. Any minor as described in the preceding sentence shall be 
deemed to have sustained damages of no less than $50,000 in value." See discussion 
of rules of statutory construction in part III.A. herein. See subsection (f)(2) of 18 U.S.C. 
§2252A, entitled Certain activities relating to material constituting or containing child 
pornography, also contained in Chapter 110, Part I, Crimes, within which specific 
reference is made to "compensatory and punitive damages" in setting forth the relief 
which may be afforded to a plaintiff in bringing a civil action under §2252A(f). 
EFTA00175347

Case 9:08-cv-80811-KAM 
Document 47 
Entered on FLSD Docket 03/12/2009 
Page 13 of 21 
v. Epstein, et al. 
R/13 
statute prohibits a number of activities involving criminal 'proceeds." Id, at 2023. Noting 
that the term "proceeds" was not defined in the statute, the Supreme Court stated the 
well settled principle that "when a term is undefined, we give it its ordinary meaning." Id, 
at 2024. Under the ordinary meaning principle, the government's position was that 
proceeds meant "receipts," while the defendant's position was that proceeds meant 
"profits." The Supreme Court recognized that under either of the proffered "ordinary 
meanings," the provisions of the federal money-laundering statute were still coherent, 
not redundant, and the statute was not rendered "utterly absurd." 
Under such a 
situation, citing to a long line of cases and the established rule of lenity, "the tie must go 
to the defendant." Id, at 2025. See portion of Court's opinion quoted above. "Because 
the 'profits' definition of 'proceeds' is always more defendant friendly that the 'receipts' 
definition, the rule of lenity dictates that it should be adopted." Id. 
Plaintiffs position would subject Defendant EPSTEIN to a punishment that is not 
clearly prescribed — an unwritten multiplier of the "actual damages" or the presumptive 
damages. The rule of lenity requires that Defendant's interpretation of the remedy 
afforded under §2255 be adopted. 
In addition, under the Due Process Clause's basic principle of fair warning - 
... a criminal statute must give fair warning of the conduct that it makes a 
crime ... . As was said in United States v. Harriss, 347 U.S. 612, 617, 74 
S.Ct. 808, 812, 98 L.Ed. 989, 
'The constitutional requirement of definiteness is violated by a criminal 
statute that fails to give a person of ordinary intelligence fair notice that 
his contemplated conduct is forbidden by the statute. The underlying 
principle is that no man shall be held criminally responsible for conduct 
which he could not reasonably understand to be proscribed.' 
EFTA00175348

Case 9:08-cv-80811-KAM 
Document 47 
Entered on FLSD Docket 03/12/2009 
Page 15 of 21 
IS. 
v. Epstein, et al. 
Page 15 
offenses outlined in Chapter 800 of the Federal Codes, as well as those designated in 
Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01; and §827.04." In ¶203 
Plaintiff also alleges that Defendant's "tortious commission of sexual battery upon 
were (sic) done willfully and maliciously." 
Supporting Defendant's position that Plaintiff has failed to state a cause of action 
in Count )OO0, 18 U.S.C. O2241(c), not §2241 in its entirety, as discussed above, is 
one of the predicate acts, along with 2242, 2243, 2421, and 2423, designated in the 
federal civil remedy statute — 18 U.S.C. §2255. Plaintiff attempted and failed to allege 
such a claim in the previous counts. Defendant can find no criminal offenses in any 
"Chapter 800 of the Federal Codes" which give rise to a civil cause of action. 
The same is true for Plaintiffs reference to the Florida Statutes. Not one of the 
statutes referenced creates a private cause of action or affords a civil remedy on behalf 
of the alleged victim of the criminal offense." (Except for Florida Statute §39.01, all of 
the statutes referenced by Plaintiff are contained Title XLVI. Crimes of the Florida 
Statutes). The referenced criminal statutes set forth acts subject to criminal prosecution 
and the criminal penalties therefor, if proven. See generally Am. Home Assurance Co. 
v. Plaza Materials Coro. 908 So.2d 360, 374 (Fla. 2005)("not every statutory violation 
carries a civil remedy"); Miami Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 
1985)(violation of Florida's criminal extortion statute does not give rise to civil cause of 
' Florida Statutes O796.03 — Procuring person under age 18 for prostitution; 796.04 —
Forcing, compelling, or coercing another to become a prostitute; 796.045 (which did not 
become effective until Oct. 1, 2004) - Sex trafficking; penalties; 796.07 — Prohibiting 
prostitution, etc.; evidence; penalties; definitions; and §39.01, entitled "Definitions," is 
contained in Title V — Judicial Branch, Chapter 39 - "Proceedings relating to Children." 
EFTA00175349

Case 9:08-cv-80811-KAM 
Document 47 
Entered on FLSD Docket 03/12/2009 
Page 17 of 21 
. v. Epstein, et al. 
0•17 
Defendant EPSTEIN, but rather allows Plaintiff to attempt to assert a single civil remedy 
if she can prove a violation of any of the statutory enumerated predicate acts. Further, 
Plaintiff has failed to sufficiently allege a requisite predicate act under §2255. In 
addition, §2255 does not allow for recovery of punitive damages. Count XXXI is also 
subject to dismissal with prejudice for failure to state a cause of action, as Plaintiff has 
failed to allege a legally viable or recognizable cause of action. 
WHEREFORE, Defendant requests that this Court grant his motion to dismiss 
Counts I through XXXI, or alternative motion for more definite statement, and motion to 
strike. 
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 m'day of  March 2009: 
Richard Horace Willits, Esq. 
Richard H. Willits, P.A. 
2290 101h Avenue North 
Suite 404 
L 33461 
Fax: 
Counsel for Plaintiff I.M.A. 
reelrhwAhotmail.com 
Jack Scarola, Esq. 
Jack P. Hill, Esq. 
Searcy Denney 
Scarola 
Barnhart 
Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
ach, FL 33409 
Fax: 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
B-ach, FL 33401-5012 
Fax: 
jaqesqAbellsouth.net 
Counsel for Defendants Jeffrey Epstein 
and 
Bruce Reinhart, Esq. 
& Bruce E. Reinhart, P.A. 
250 S. Australian Avenue 
Suite 1400 
ach, FL 33401 
Fax: 
EFTA00175350

Case 9:08-cv-80811-KAM 
Document 47 
Entered on FLSD Docket 03/12/2009 
Page 19 of 21 
. v. Epstein, et al. 
Page 19 
attained the age of 16 years (and is at least 4 years younger than the person so 
engaging), or attempts to do so, shall be fined under this title and imprisoned for not 
less than 30 years or for life. If the defendant has previously been convicted of another 
Federal offense under this subsection, or of a State offense that would have been an 
offense under either such provision had the offense occurred in a Federal prison, unless 
the death penalty is imposed, the defendant shall be sentenced to life in prison. 
§ 2242. Sexual abuse 
Whoever, in the special maritime and territorial jurisdiction of the United States or in 
a Federal prison, or in any prison, institution, or facility in which persons are held in 
custody by direction of or pursuant to a contract or agreement with the head of any 
Federal department or agency, knowingly--
(1) causes another person to engage in a sexual act by threatening or placing that 
other person in fear (other than by threatening or placing that other person in fear that 
any person will be subjected to death, serious bodily injury, or kidnapping); or 
(2) engages in a sexual act with another person if that other person is--
(A) incapable of appraising the nature of the conduct; or 
(B) physically incapable of declining participation in, or communicating 
unwillingness to engage in, that sexual act; 
or attempts to do so, shall be fined under this title and imprisoned for any term of years 
or for life. 
§ 2243. Sexual abuse of a minor or ward 
(a) Of a minor.--Whoever, in the special maritime and territorial jurisdiction of the 
United States or in a Federal prison, or in any prison, institution, or facility in which 
persons are held in custody by direction of or pursuant to a contract or agreement with 
the head of any Federal department or agency, knowingly engages in a sexual act with 
another person who--
(1) has attained the age of 12 years but has not attained the age of 16 years; and 
(2) is at least four years younger than the person so engaging; 
or attempts to do so, shall be fined under this title, imprisoned not more than 15 years, 
or both. 
(b) Of a ward.--Whoever, in the special maritime and territorial jurisdiction of the United 
States or in a Federal prison, or in any prison, institution, or facility in which persons are 
held in custody by direction of or pursuant to a contract or agreement with the head of 
any Federal department or agency, knowingly engages in a sexual act with another 
person who is--
EFTA00175351

Case 9:08-cv-80811-KAM 
Document 47 
Entered on FLSD Docket 03/12/2009 
Page 21 of 21 
ME. v. Epstein, et al. 
Page 21 
(c) Engaging in illicit sexual conduct In foreign places.--Any United States citizen or 
alien admitted for permanent residence who travels in foreign commerce, and engages 
in any illicit sexual conduct with another person shall be fined under this title or 
imprisoned not more than 30 years, or both. 
(d) Ancillary offenses.--Whoever, for the purpose of commercial advantage or private 
financial gain, arranges, induces, procures, or facilitates the travel of a person knowing 
that such a person is traveling in interstate commerce or foreign commerce for the 
purpose of engaging in illicit sexual conduct shall be fined under this title, imprisoned 
not more than 30 years, or both. 
(e) Attempt and conspiracy.--Whoever attempts or conspires to violate subsection (a), 
(b), (c), or (d) shall be punishable in the same manner as a completed violation of that 
subsection. 
(f) Definition.--As used in this section, the term "illicit sexual conduct" means (1) a 
sexual act (as defined in section 2246) with a person under 18 years of age that would 
be in violation of chapter 109A if the sexual act occurred in the special maritime and 
territorial jurisdiction of the United States; or (2) any commercial sex act (as defined in 
section 1591) with a person under 18 years of age. 
(g) Defense.--In a prosecution under this section based on illicit sexual conduct as 
defined in subsection (f)(2), it is a defense, which the defendant must establish by a 
preponderance of the evidence, that the defendant reasonably believed that the person 
with whom the defendant engaged in the commercial sex act had attained the age of 18 
years. 
EFTA00175352

Ci.se 9:08-cv-80811-KAM 
Document 81 
Entered on FLSD Docket 05/13/2009 
Page 1 of 7 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CIV-80811-MARRAIJOHNSON 
Plaintiff, 
v. 
EPSTEIN and ME 
Defendants, 
Defendant, Jeffrey Enstein's Reply to Plaintiff's Response In Opposition To Defendant's Motion To 
Stay And/Or Continue Action For Time Certain With Incorporated Memorandum Of Law 
Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his 
undersigned attorneys, hereby files his Reply to Plaintiff's Response In Opposition to 
Defendant's Motion to Stay and/or Continue Action (DE 64), and states: 
I. 
Introduction and Argument 
Plaintiff, in the instant matter, did not draft her own Response to the Motion to Stay. 
Instead, Plaintiff incorporated Plaintiffs' responses to the motion to stay in certain related matters 
(DE 64), and adopted those arguments as her own.I
Plaintiff's Response in Opposition challenging the stay should not prevail when 5m
Amendment principles are at issue and when there exists a real, substantial and not remote 
possibility that Epstein may face criminal prosecution by the United States Attorneys' Office 
("USAO") if the USAO unilaterally determines that Epstein somehow violated that certain Non-
Prosecution Agreement dated June 30, 2008 ("NPA") and/or if Epstein is forced to waive those 
5th Amendment rights and participate in civil discovery in order to defend this civil action. 
Accordingly, Epstein adopts his arguments set forth in the Reply to Jane Doe's Response In Opposition 
filed in 08-CIV-80893 (DE 54) and incorporates same herein by reference. 
EFTA00175353