EFTA00175470

CM/ECF - Live Database - flsd 
Page 1 of 5 
LSS 
U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE #: 9:08-cv-80811-KAM 
v. Epstein et al 
Assigned to: Judge Kenneth A. Marra 
Cause: 28:1332 Diversity 
Plaintiff 
V. 
Defendant
Jeffrey Epstein 
Date Filed: 07/21/2008 
Jury Demand: Plaintiff 
Nature of Suit: 360 P.I.: Other 
Jurisdiction: Diversity 
represented by Richard Horace Willits 
Richard H Willits PA 
2290 10th Avenue North 
Suite 404 
Lak 
o h FL 33461 
Fax: 
Email: 
LEAD 
ATTORNEY TO BE NOTICED 
represented by Bruce Reinhart 
Bruce E. Reinhart, P.A. 
250 S. Australian Avenue 
Suite 1400 
West Palm Beach , FL 33401 
Fax: 
Email 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Guy Alan Lewis 
Lewis Tein 
3059 Grand Avenue 
Suite 340 
Coconut Grove , FL 33133 
Fax: 442-6744 
Email: 
LEAD ATTORNEY 
https://ectflsd.uscourts.gov/cgi-bin/DktRpt.p17254617312841442-L_801_0-1 
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ATTORNEY TO BE NOTICED 
Jack Alan Goldberger 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach , FL 33401-5012 
Fax: 835-8691 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Michael Ross Tein 
Lewis Tein 
3059 Grand Avenue 
Suite 340 
Coconut Grove , FL 33133 
Email:
Fax: 4 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Michael James Pike 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Fax: 515-3148 
Email: [email protected] 
ATTORNEY TO BE NOTICED 
Robert Deweese Critton , Jr. 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Defendant
Fax: 
Email: 
ATTORNEY TO BE NOTICED 
represented by Bruce Reinhart 
(See above for address) 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
https://eclfisd.uscourts.gov/cgi-bin/DktRpt.pl?254617312841442-L801 3)-1 
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EFTA00175471

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Guy Alan Lewis 
(See above for address) 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Jack Alan Goldberger 
(See above for address) 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Michael Ross Tein 
(See above for address) 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Date Filed 
# 
clear Docket Text 
07/21/2008 
I 
r
NOTICE OF REMOVAL Filing fee $350 Receipt#: 724505, filed by 
Jeffrey Epstein, 
.(rb) (Entered: 07/21/2008) 
07/22/2008 
2 
r
ORDER of Instructions. Signed by Judge William J. Zloch on 7/22/2008. 
(be) (Entered: 07/22/2008) 
07/25/2008 
3 r
MOTION for Hear' 
Defendants' Request for Oral Argument by Jeffrey 
Epstein, 
. (Tein, Michael) (Entered: 07/25/2008) 
07/25/2008 
4 
r 
MOTION for Extension of Time to File Answer Defendants Motion for 
Enlargement of '
Answer or Otherwise Respond to Complaint by 
Jeffrey Epstein, 
. (rein, Michael) (Entered: 07/25/2008) 
07/25/2008 
5 r
NOTICE by Jeffrey Epstein, 
Notice of Related Actions 
(Tein, Michael) (Entered: 07/25/2008) 
07/25/2008 
6 
Sealed Document. (igo) (Entered: 07/25/2008) 
07/25/2008 
7 
Sealed Document. (igo) (Entered: 07/25/2008) 
07/29/2008 
8 
r 
ORDER denying without prejudice 4 Motion for Extension of Time to 
Respond to Complaint. Signed by Judge William J. Zloch on 7/28/2008. 
(be) (Entered: 07/29/2008) 
07/30/2008 
2 
F 
MOTION for Extension of Time to File Answer Defendants' Renewed 
Motion for Enlargement of Ti 
r Otherwise Respond to 
Complaint by Jeffrey Epstein, 
(Attachments: # I Text of 
Proposed Order Proposed Order)(Tein, Michael) (Entered: 07/30/2008) 
07/30/2008 
10 
PAPERLESS ORDER denying a Motion for Hearing. Signed by Judge 
William J. Zloch on 7/30/2008. (be) (Entered: 07/30/2008) 
08/06/2008 
I I 
PAPERLESS ORDER granting 2 Motion for Extension of Time to 
Respond to Complaint. Signed by Judge William J. Zloch on 8/6/2008. 
(be) (Entered: 08/06/2008) 
https://ecf.fisd.uscourts.gov/cgi-bin/DktRpt.p17254617312841442-L_801_0-1 
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08/07/2008 
12 
r
MOTION to Reassign Case TO JUDGE KENNETH MARRA by_.. 
(Willits, Richard) (Entered: 08/07/2008) 
08/07/2008 
D 
r 
MEMORANDUM in Opposition re 6 Seaainent, 7 Sealed 
Document TO MOTION TO STAY filed b 
(Willits, Richard) 
(Entered: 08/07/2008) 
08/14/2008 
14 
PAPERLESS ORDER denying 12 Motion to Reassign Case. Signed by 
Judge William J. Zloch on 8/14/2008. (be) (Entered: 08/14/2008) 
08/18/2008 
15 
r
MOTION for Extension of Time to File Reply Defendants' Motion for An 
Enlargement of Time to File R 
al Because of Tropical 
Storm Fay by Jeffrey Epstein, 
(Attachments: # 1 Text of 
Proposed Order)(Tein, Michae 
nter : 8/18/2008) 
08/18/2008 
1() 
I_ 
SCHEDULING REPORT- Rule 26(1). (rein, Michael) (Entered: 
08/18/2008) 
08/20/2008 
17 
Sealed Document. (rb) (Entered: 08/20/2008) 
08/25/2008 
18 
PAPERLESS ORDER granting 15 Motion for Extension of Time to 
Respond. Signed by Judge William J. Zloch on 8/25/2008. (be) (Entered: 
08/25/2008) 
08/27/200s 
19 
r
NOTICE by Jeffrey Epstein Notice of Appearance (Pike, Michael) 
(Entered: 08/27/2008) 
08/28/2008 
Clerks Notice of Docket Correction and Instruction to Filer re 19 Notice 
(Other) filed by Jeffrey Epstein. Error - Wrong Event Selected; 
Correction - Redocketed by Clerk as NOTICE of Attorney Appearance. 
Instruction to Filer - In the future, please select the proper event. It is not 
necessary to refile this document. (ail) (Entered: 08/28/2008) 
08/28/2008 
20 
NOTICE of Attorney Appearance by Michael James Pike, Robert 
Deweese Critton, Jr on behalf of Jeffrey Epstein. Redocketed SEE Image 
2 (ail) (Entered: 08/28/2008) 
09/03/2008 
21 
r 
ORDER REASSIGNING CASE. Case reassigned to Judge Kenneth A. 
Marra for all further proceedings. Judge William J. Zloch no longer 
assigned to case. Signed by Judge William J. Zloch on 8/29/2008. (tb) 
(Entered: 09/03/2008) 
09/06/2008 
22 
r
MOTION to Preserve Evidence by 
(Willits, Richard) (Entered: 
09/06/2008) 
09/06/2008 
23 
MOTION to Expedite certain discovery by 
(see image 22 ) (tb) 
(Entered: 09/09/2008) 
09/09/2008 
Clerks Notice of Docket Correction and Instruction to Filer re 22 
MOTION to Preserve Evidence filed by.
,... Error - Motion with 
Multiple Reliefs Filed as One Relief; orrection - Additional relief(s) 
_23_ docketed by Clerk. Instructions to filer - In the future, please 
select all applicable reliefs. It is not necessary to refile this document. (tb) 
(Entered: 09/09/2008) 
Intps://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?254617312841442-L 801_0-1 
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CM/ECF - Live Database - flsd 
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09/15/2008 
24 r 
ORDER denying in part 22 Motion to Preserve Evidence; granting in part 
23 Motion to Expedite. Signed by Judge Kenneth A. Marra on 9/14/08. 
(ir) (Entered: 09/15/2008) 
or 
View Selected 
Download Selected 
PACER Service Center 
Transaction Receipt 
10/08/2008 17:27:40 
PACER Login: du4480 
Client Code: 
Description: 
Docket Report Search Criteria: K 
9:AM08-c 
v-80811-
Billable Pages: 3 
Cost: 
10.24 
https://ect flsd.uscourts.gov/cgi-bin/DktRpt.p17254617312841442-L_801_0-1 
10/8/2008 
EFTA00175474

Case 9:08-cv-8L .1-KAM 
Docurr.... it 24 
Entered L. FLED Docket Og .../2008 
Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NO. 08-80811-CIV-MARRA/JOHNSON 
Plaintiff, 
V. 
JEF 
and 
Defendants. 
ORDER 
THIS CAUSE comes before the Court on Plaintiff's Motion to Preserve Evidence and 
Expedite Certain Discovery (DE 22), filed September 6, 2008. Plaintiff represents that 
Defendants have not agreed to the relief requested in this motion on the basis that Defendants 
believe the motion is moot because of another order recently entered by the Court in Doe 11 
Epstein, NO. 08-80804-CIV-MARRA. The Court has carefully considered the motion and is 
otherwise fully advised in the premises. 
It is ORDERED AND ADJUDGED that Plaintiff's Motion (DE 22) is GRANTED IN 
PART. Defendants are directed to provide duplicates of all evidence subject to this Court's 
protective order in Doe 1 Epstein, No. 08-80804-CIV-MARRA (Sept. 5, 2008) to Plaintiff 
should said evidence be returned to Defendants by the State of Florida. Plaintiff's Motion is 
DENIED IN PART AS MOOT as to the request to preserve evidence since the evidence in 
EFTA00175475

Case 9:08-cv-8L I1-KAM 
Down', it 24 
Entered G.. ELSD Docket 09, .A2008 
Page 2 of 2 
question is already subject to a protective order issued by this Court. 
DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, 
Florida, this 14ih day of September, 2008. 
fl
 
KENNETH A. MARRA 
United States District Judge 
Copies to: 
all counsel of record 
EFTA00175476

Case 9:08-cv-86,.. .1-KAM 
Docum,..it 22 
Entered u.. rLSD Docket 09,,,/2008 
Page 1 of 4 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO: 08-80811-CIV-MARRA/JOHNSON 
C.M.A. 
PLAINTIFF 
vs. 
and 
DEFENDANTS 
PLAINTIFF'S MOTION TO PRESERVE EVIDENCE 
AND EXPEDITE CERTAIN DISCOVERY 
WITH INCORPORATED MEMORANDUM 
Plaintiff 
moves, pursuant to Rules 26 and 34 to Preserve Evidence 
and Expedite the Discovery of this Evidence and states: 
1. Defendants removed this action to federal court. 
2. This case was recently reassigned to this division by the Honorable 
William Zloch. 
3. This is one of several cases pending in this division which alleges sexual 
abuse of a female minor by the defendant JEFFREY EPSTEIN. 
4. It has come to the attention of the undersigned that Defendant JEFFREY 
EPSTEIN filed a Motion with the Florida State Court to return the evidence seized 
at his home in conjunction with his criminal prosecution. With respect to the 
details of EPSTEIN's motion, Plaintiff respectfully requests this court to take 
EFTA00175477

Case 9:08-cv-8L .1-KAM 
Doom_ ..t 22 
Entered L. FLSD Docket Oth . )2008 
Page 2 of 4 
judicial notice of a similar motion and its attachments filed at Docket Entry 12 in 
the separate case filed in this court by the name of JANE DOE, a/k/a. JANE DOE 
NO. 1 v. JEFFREY EPSTEIN et al. Case NO. 08-80804-CIV-MARRADOMISON 
5. This evidence is relevant and critical to the prosecution of not only the 
instant claim, but for other suits filed against Defendant EPSTEIN, including but 
not limited to the Florida RICO claims filed in State Court. 
6. As stated in the certificate, the undersigned has conferred with counsel 
for EPSTEIN. They take the position that this motion would be moot because of an 
order recently entered in JANE DOE, a/k/a. JANE DOE NO. 1 v. JEFFREY 
EPSTEIN et al. Case NO. 08-80804-CIV-MARRA/JOHNSON. However, 
respectfully believes that an enforceable order is needed in this particular 
case. In addition, she requests a more detailed order which includes all of the 
numerous law firms representing the defendants EPSTEIN and 
WHEREFORE, Plaintiff respectfully request the Court grant her Motion to 
Preserve of all the seized Evidence identified in the Palm Beach Police Department 
Property Receipt attached to the Motion to Preserve Evidence filed at Docket Entry 
#12 in the case of JANE DOE, a/k/a. JANE DOE NO. 1 v. JEFFREY EPSTEIN 
et al. Case NO.08-80804-CIV-MARRA/JOHNSON should it be Returned to 
EPSTEIN by the State Court, and expedite the duplication of this evidence 
immediately upon its return, in advance of any Rule 26 conference. 
EFTA00175478

Case 9:08-cv-86, .1-KAM 
DocurL.,t 22 
Entered u. FLSD Docket 09, J2008 
Page 3 of 4 
MEMORANDUM OF LAW 
Pursuant to Rules 26, 30 and 34, of the Federal Rules of Civil Procedure, 
this court has the authority to modify the normal time limitations under the Rules. 
See AT&T Mobility LLC v. Dynamic Cellular Corp., 2008 WL 2139518 (S.D. Fla. 
2008); see also Tradone Wireless, Inc. v.King Trading, Inc., 2008 WL 918243 
(N.D. Tex. 2008). Additionally, when there is a good faith belief that evidence may 
be lost the Court has the authority to enter an Order preserving such evidence. Id. 
at 1. An injunction is not required nor are the elements of an injunction necessary 
before entering an Order preserving such evidence. Id. at 2. 
Given that Defendant EPSTEIN has plead guilty and is currently serving a 
year in jail based on the charges which form the foundation Plaintiffs (and many 
other Plaintiffs') claims, it is reasonable to assume the State's seized evidence is 
extremely harmful to Defendant EPSTEIN. 
As a result, without a Protective Order Defendant EPSTEIN has no reason to 
keep or maintain this negative evidence; Plaintiff has put Defendant EPSTEIN on 
notice that this evidence is relevant to the instant action and any destruction could 
potentially constitute spoliation. If this evidence were destroyed Plaintiff would be 
severely prejudiced. 
Dated: September 6, 2008 
Respectfully submitted, 
By: s/Richard H. Willits 
Richard H. Willits (FL Bar No. 139888) 
RICHARD H. WILLITS, P.A. 
Attorne for Plaintiff 
2290 10th Ave. North, Suite 404 
Tel: 
Fax: 561-582-7600 
EFTA00175479

Case 9:08-cv-8L.1-KAM 
Docurt.....t 22 
Entered ca. rLSD Docket oa J2008 
Page 4 of 4 
CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1 
I hereby certify that I conferred with opposing counsel by telephone on August 7, 
2008 concerning a good faith effort to resolve the Motion to Stay, and they oppose 
the motion on the ground that it would be moot. 
s/Richard H. Willits 
CERTIFICATE OF SERVICE 
I hereby certify that on September 6, 2008, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF, I also certify that the 
foregoing document is being served this day to all parties on the attached Service 
List in the manner specified, either via transmission of 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/Richard H. Willits 
SERVICE LIST 
Michael Tein, Esq. --
Jack Goldberger, Esq. 
Bruce Reinhart, Esq. — 
Michael Pike, Esq. 
Robert Critton, Esq. 
EFTA00175480

D'ase 9:08-cv-8(,_ .1-KAM 
Docu....:nt 1 
Entered oi. • LSD Docket 07i..'2008 FIFA/All Ogif0 D.C. 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 
C.M.A., 
08-80811-Civ-ZLOCH/SNOW 
vs. 
Plaintiff, 
N and 
Defendants. 
July 21, 2008 
STITCH M. LARIMORE 
CLERK V.S. DIST. CT. 
S.O. OF FLA. - MIAMI 
NOTICE OF REMOVAL 
In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(aX1), the defendants, 
Jeffrey Epstein and 
hereby remove this action' from Palm Beach 
County Circuit Court to the United States District Court for the Southern District 
of Florida, and respectfully state as follows: 
1. 
This case is within the original jurisdiction of this Court. 
This case is properly removable because it falls within the original 
jurisdiction of the United States District Court for the Southern District of Florida. 
See 28 U.S.C. § 1332(a)(1) (establishing that federal district courts have original 
v. Epstein et at, Case No. 50 2008 CA 005240 XXXX MB (Fla. 15th Cir. Ct. 
filed Feb. 21, 2008). 
LeV4tir ifixte. 
7059 GIMDAvniui, Sun 340, Cowart Gem. RONDA 33133 
1 0140 
EFTA00175481

7
Ce Case 9:08-cv-8(.... .1-KAM 
Douai...int 1 
Entered ol. . LSD Docket 07i._ ./2008 
Page 2 of 40 
jurisdiction over cases where the amount "in controversy [is more than $75,000] . . 
. and [when the controversy] is between citizens of different states"). 
2. 
The amount in controversy in this action exceeds $75,000. 
The Complaint contains a generic prayer for relief.2 It is clear, however, that 
the plaintiff seeks more than $75,000 in damages. This case seeks damages in 
connection with alleged sexual misconduct. (Compl. ¶¶ 6-7,) 
The Complaint 
alleges that 
has "suffered mental anguish, mental pain and suffering, 
psychic trauma, and a loss of the capacity for the enjoyment of life." (Compl. ¶ 9.) 
These are serious allegations. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. 
Supp, 2d 812, 820 (N.D. III. 2007) (determining, in the context of diversity 
jurisdiction, that the $75,000 threshold had been satisfied, and "clearly 
[surpassed]," based on "the nature of the injuries alleged" in the complaint); see 
also Williams v. Best Buy Co., Inc., 269 F.3d 1316, 1319 (11th Cir. 2001) ("When 
[a] complaint does not claim a specific amount of damages, removal from state 
court is proper if it is facially apparent from the complaint that the amount in 
controversy exceeds the jurisdictional requirement."). 
2 The Complaint seeks damages for "[more than] . . . $15,000." (Compl. ¶ I.) This 
boilerplate is routinely used in Florida pleading practice to trigger application of section 
26.012, Florida Statutes, the statute that establishes the jurisdictional amount required for 
filing in Florida's Circuit Court (as opposed to County Court). 
2 
Lewis Min PI. 
3059 GRANOAVIP44, Sum 340, Cocann Gaon. teem33133 
2 0140 
EFTA00175482

• 
'Case 9:08-cv-13L_ 11-KAM 
Docul..,Int 1 
Entered oh. LSD Docket 07,-.12008 
Page 3 of 40 
Further, the allegations by this plaintiff are virtually identical to allegations 
made in four separate civil actions, filed by four different plaintiffs, against Mr. 
Epstein in federal court.3 
In each of those actions, the plaintiffs are seeking 
damages in excess of $50 million - - well over the $75,000 amount-in-controversy 
requirement for diversity jurisdiction. See Jane Doe No. 2 at D.E. 1 ¶ 4; Jane Doe 
No. 3 at D.E. I ¶ 4; Jane Doe No. 4 at D.E. 1 ¶ 4; Jane Doe No. 5 at D.E. 1 ¶ 4. 
3. 
There is complete diversity. 
Diversity jurisdiction requires complete diversity. 
Carden r. Arlcoma 
Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the 
diversity statute to require 'complete diversity' of citizenship." (citing Strawbridge 
I. Curtiss, 7 U.S. (3 Cranch) 267, 267-68 (1806))); see also MacGinnitie I. Hobbs 
Group, LLC, 420 F.3d 1234, 1239 (11th Cir. 2005) (stating that "[e]omplete 
diversity requires that no defendant in a diversity action be a citizen of the same 
state as any plaintiff"). As demonstrated below, this case satisfies the statutory 
requirement of complete diversity. 
(a) 
Plaintiff= 
is a citizen of Florida. (Compl. ¶ 2.) 
3 See Jane Doe No. 2 v. Jeffrey Epstein, No. 08-CV-80119-KAM (S.D. Ha. filed Feb. 6, 
2008); Jane Doe No. 3 v. Jeffrey Epstein, No. 08-CV-80232-KAM (S.D. Ha. filed Mar. 
5, 2008); Jane Doe No. 4 v. Jeffrey Epstein, No. 08-CV-80380-KAM (S.D. Fla. filed Apr. 
14, 2008); Jane Doe No. 5 v. Jeffrey Epstein, No. 08-80381-CV-KAM (S.D. Fla. filed 
Apr. 14. 2008). 
3 
LeN70ATQin 
3059 Goma Avirem, Sent 340, Cccomit Gaovt, FICSOA 33133 
3 of 40 
EFTA00175483

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Docui...mt 1 
Entered oi. . LSD Docket 07/._ .12008 
Page 4 of 40 
(b) 
While the Complaint suggests that Mr. Epstein might be a citizen of 
New York or Florida, he is, in fact, a citizen of the U.S. Virgin Islands. 
(Epstein Aff. Ex. A.)4
(c) 
Contrary to the allegations in the Complaint, Defendan 
is a citizen of New York, not Florida. 
Stmt. Ex. B.) 
4. 
This Notice satisfies the procedural requirements of 28 U.S.C. § 
1446. 
First, in accordance with 28 U.S.C. § 1446(6), this Notice is timely. Only 
defendant Epstein has been served with process. Defendant 
has not yet 
been served. See Hill Dermaceuticals, Inc." RX Solutions, United Health Group, 
Inc., No, 6:08-cv-330-Or1-31KRS, 2008 WL 1744794, at *3 (M.D. Fla. Apr. I I, 
2008) (concluding that removal petition was timely where it was filed within 30 
days after the last defendant was served). 
Second, in accordance with section 1446(d), defendants have served this 
Notice of Removal on July 21, 2008, 
Third, in accordance with section 1446(6), all of the defendants join this 
Petition and consent to removal. 
District courts may consider affidavits and other evidence to support removal 
jurisdiction. See Sierminskil. Transouth Fin. Corp., 216 F.3d 945, 949 (1lth Cir. 2000). 
4 
lae-WrikATSin 
n. 
3059 GIVJOAYINUL Sun NO. COCONUT Cowl, <to mm 33133 
•0140 
EFTA00175484

lase 
Docui...int 1 
Entered oh . LSD Docket 07/../2008 
Page 5 of 40 
5. 
The State Court docket has been filed. 
All papers filed in the State Court are attached to this Removal Petition. 
Conclusion 
Because this is a civil action between citizens of different states, excluding 
any fraudulently joined parties, and the amount in controversy exceeds $75,000, 
exclusive of interests and costs, this Court has original jurisdiction over this action 
pursuant to 28 U.S.C. § 1332(a)(1). 
WHEREFORE, the defendants, Jeffrey Epstein and
 remove 
this case from Palm Beach Circuit Court to the United States District Court for the 
Southern District of Florida. 
Respectfully submitted, 
LEWIS TEIN, P.L. 
3059 Grand Avenue, Suite 340 
Coconut Grove, Florida 33133 
Tel: OM 
fax 305 442 67 4 
f 
By: 
GUY A. 
A. LEWIS 
MICHAEL R. TEIN 
Fla. Bar No. 993522 
5 
Lewis Teinn 
,..„ 
3059 GRAso Ay; NIA, Sun MO. CO(.09vi Govt, Fi0909 33133 
50100 
EFTA00175485

Case 9:08-cv-8L. .1-KAM 
Docu....int 1 
Entered oi. . LSD Docket 07i._.12008 
Page 6 of 40 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, Florida 33401 
Tel. 
Fax. 
By: 
Jack A. Goldberger 
Fla. Bar No. 262013 
Attorneys for Defendant Jeffrey Epstein 
BRUCE E. REINHART, P.A. 
250 South Australian Avenue 
Suite 1400 
West Palm Beach, Florida 33401 
Tel. 
Fax. 
By: 
Bruce E. Reinhart 
Fla. Bar No. 10762 
Attorneys for Defendant 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that the foregoing document is being served this day, 
July 21, 2008, on counsel of record identified on the service list by U.S. Mail. 
Michael R. Tein 
6 
Levyyst_Xsin n. 
34359 Gnaw° MINIX, Simi 340. COI OW, G.ovr, I COMA 33133 
S of 40 
EFTA00175486

Case 9:08-cv-86,- .1-KAM 
Docul...int 1 
Entered or. . LSD Docket 07r,_ ,i2008 
Page 7 of 40 
Service list 
Richard H. Willits, Esq. 
Richard H. Willits, P.A. 
2290 10th Avenue North, Suite 404 
Lake 
33461 
Fax: 
Counsel for Plaintiff C. M.A. 
7 
,,,, 
n. 
3059 GPANDAvl wt. Son 340, COCONUT Gam, FLOPS 33133 
Tot 40 
EFTA00175487

Case 9:08-cv-86, .1-KAM 
Docti....int 1 
Entered or. . LSD Docket 07r,_.12008 
Page 8 of 40 
EXHIBIT A 
I ol 40 
EFTA00175488

Case 9:08-cv-8L .1-KAM 
Docui,.,Int 1 
Entered or. . LSD Docket 07r- .12008 
Page 9 of 40 
AFFIDAVIT OF JEFFREY EPSTEIN 
I, Jeffrey Epstein, being duly sworn, do depose and state as follows: 
1. 
My name is Jeffrey Epstein, and I am over 18 years of age and 
otherwise competent to testify. 
2. 
I am a citizen and resident of the U.S. Virgin Islands. 
3. 
My permanent address is in the U.S. Virgin Islands. 
FURTHER AFFIANT SAYETH NAUGHT. 
Sworn before me this /1 day of July 2008 
Gir(12,.; 
Notary Public 
State of Florida 
My commission expires: 
NOTARY PLIBUC-S !ATE OF FLORIDA 
r 
'''''' Michael R. Tein 
fi 
iCommissionODD581058 
„,„," Expires: AUG. 03, 20
B0NDED 
THAU 
ATLANTIC 
BONDLNG 
CO., 
INC 
Sold. 
EFTA00175489