EFTA00175214

• Case 9:09-cv-80469-KAM 
Document 13 
Entered on FLSD Docket 05/06/2009 
Page 21 of 29 
Jane Doe II v Epstein, et al. 
Page 21 
had intended to abrogate the forum non conveniens doctrine in a §2255 action; the 
District Court noted that the statute does not contain a mandatory venue provision. Had 
Congress wanted to get rid of the forum non-conveniens doctrine, it would have said so 
in the statute. Also, in Smith v. Husband 428 F.Supp. 432; and 376 F.Supp.2d 603, the 
plaintiff invoked "the accompanying civil remedy for these criminal violations, stating that 
she has sustained and continues to sustain physical and mental damages, humiliation, 
and embarrassment as a result of Defendant's criminal acts." In other words, she 
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. 
EFTA00175294

Case 9:09-cv-80469-KAM 
Document 13 
Entered on FLSD Docket 05/06/2009 
Page 23 of 29 
Jane Doe II v. Epstein, et al. 
Page 23 
commerce, or within the special maritime and territorial jurisdiction of the United States 
knowingly persuades, induces, entices, or coerces any individual who has not attained 
the age of 18 years, to engage in prostitution or any sexual activity for which any person 
can be charged with a criminal offense, or attempts to do so, ... 
Plaintiff appears to be relying solely on an "agreement with the United States 
Attorney's Office to not contest liability for claims brought exclusively pursuant to 18 
U.S.C. §2255, in exchange for avoiding federal prosecution under 18 U.S.C. §2422(b)." 
Complaint, ¶15. As noted above herein, Plaintiff already has additional claims against 
EPSTEIN pending in state court. See Exhibit A hereto. Even taking Plaintiff's allegation 
in paragraph 15 as true, Plaintiff is not proceeding exclusively under §2255. 
Accordingly, under 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. In the alternative, pursuant to constitutional law principles of statutory 
interpretation, 18 U.S.C. §2255 Is required to be interpreted as creating a 
single "civil remedy" or cause of action on behalf of a minor plaintiff 
against a defendant. The "civil remedy" afforded is not on a "per violation" 
or "per incident" basis. 
As set forth above, it is Defendant's position that the text of 18 U.S.C. §2255 
does not allow a Plaintiff to pursue the damages afforded under the statute on a "per 
violation" or "per incident" basis. In the alternative, if one were to assume that the 
language of §2255 were vague or ambiguous, under the constitutional based 
protections of due process, judicial restraint, and the rule of lenity applied in construing 
a statute, Defendant's position as to the meaning of the statute would prevail over 
EFTA00175295

Case 9:09-cv-80469-KAM 
Document 13 
Entered on FLSD Docket 05/06/2009 
Page 25 of 29 
Jane Doe II v. Epstein, et al. 
Page 26 
Plaintiffs position would subject Defendant EPSTEIN to a punishment that is not 
clearly prescribed — an unwritten multiplier of the "actual damages" or the presumptive 
minimum damages. The rule of lenity requires that Defendant's interpretation of the 
remedy afforded under §2255 be adopted. As noted above, Plaintiffs interpretation 
would allow Plaintiff to multiply her recovery without any regard to what the actual 
damages are. 
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.' 
Thus we have struck down a [state] criminal statute under the Due Process 
Clause where it was not 'sufficiently explicit to inform those who are subject 
to it what conduct on their part will render them liable to its penalties.' 
Connally v. General Const. Co., 269 U.S. 385, 391, 46 S.Ct. 126, 127, 70 
L.Ed. 322. We have recognized in such cases that 'a statute which either 
forbids or requires the doing of an act in terms so vague that men of common 
intelligence must necessarily guess at its meaning and differ as to its 
application violates the first essential of due process of law,' ibid., and that 
'No one may be required at peril of life, liberty or property to speculate as to 
the meaning of penal statutes. All are entitled to be informed as to what the 
State commands or forbids.' Lanzetta v. New Jersey, 306 U.S. 451, 453, 59 
S.Ct. 618, 619, 83 L.Ed. 888. 
Thus, applying these well-entrenched constitutional principles of statutory 
interpretation and application, Plaintiff's cause of action attempting to multiply the 
presumptive amount of damages is required to be dismissed for failure to state a cause 
of action. 
EFTA00175296

Case 9:09-cv-80469-KAM 
Document 13 
Entered on FLSD Docket 05/06/2009 
Page 27 of 29 
Jane Doe II v. Epstein, et al. 
Page 27 
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 gpecified via transmission of Notices of Electronic Filing generated by CM/ECF 
on this 
day of  44.4   2009: 
Isidro M. Garcia, Esq. 
Garcia Law Firm, P.A. 
224 Datura Street, Suite 900 
ach, FL 33401 
F 
isidrogarcia ,bellsouth.net 
Counsel for Plaintiff 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, FL 33401-5012 
Fax 
south.net 
Co-Counsel for Defendant Jeffrey Epstein 
Respectful 
By: 
ROBERT D. 
ITTON, JR., ESQ. 
Florida Bar 
. 224162 
rcrit(bcIcla .com 
MICHAEL J. PIKE, ESQ. 
Bar #6 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 N. Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
ax: 
(Co-counsel for e endant effrey Epstein) 
ENDNOTES: 
1 In paragraph 11 of her Complaint, Jane Doe II alleges 
'From about June, 2003 
until about February, 2005, Defendants, EPSTEIN and 
persuaded, induced, or 
EFTA00175297

Case 9:09-cv-80469-KAM 
Document 13 
Entered on FLSD Docket 05/06/2009 
Page 29 of 29 
Jane Doe II v. Epstein, et al. 
Page 29 
102, 112 Stat. 2975; Apr. 30, 2003, Pub.L. 108-21, Title I, § 103(a)(2)(A), (B), (b)(2)(A), 
117 Stat. 652, 653.) 
Amendments 
2006 Amendments. Subsec. (b). Pub.L. 109-248, § 203, struck out "not less than 5 
years and not more than 30 years" and inserted "not less than 10 years or for life". 
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Page 1 of 7 
AEV 
U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE #: 9:09-cv-80469-KAM 
Doe II v. Epstein et al 
Assigned to: Judge Kenneth A. Main 
Lead case: 9:08-cv-80119-ICAM 
Member case: (View Member Case) 
Cause: 28:1331 Federal Question 
Plainti 
Jane Doe II 
V. 
Defendant 
Jeffrey Epstein 
Date Filed: 03/24/2009 
Jury Demand: Plaintiff 
Nature of Suit: 360 P.I.: Other 
Jurisdiction: Federal Question 
represented by Isidro Manuel Garcia 
Garcia Elkins & Boehringer 
224 Datura Avenue 
Suite 900 
West Palm Beach , FL 33401 
I
-
Email:11111 
LEAD 
ATTORNEY TO BE NOTICED 
represented by Michael James Pike 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Email: 
LEAD
ATTORNEY TO BE NOTICED 
Robert Deweese Critton , Jr. 
Burman Critton Luther & Coleman 
515 N Flagler Drive 
Suite 400 
https://ecf.flsd.useouris.govicgi-bin/DIctRpt.p1T945531146089634-L_801_0-1 
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EFTA00175299

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Defendant 
ME= 
Amicus
United States of America 
West Palm Beach , FL 33401-2918 
ax: 
Emai : 
LEAD 
ATTORNEY TO BE NOTICED 
represented by ! 
!RI
 
PeStates Atton”tkffice 
500 East Broward Blvd 
7th Floor 
Ft Lauderdale , FL 33394 
smi ext. 3546 
Email: 
RWIllomm 
ATTORNEY TO BE NOTICED 
Date Filed 
# clear Docket Text 
03/24/2009 
1 
r
" 
COMPLAINT against Jeffrey Epstein, 
Filing fee $ 350.00. 
Receipt#: 725609, filed by Jane Doe II. J 
ntere : 03/25/2009) 
03/24/2009 
2 r
Summons Issued as to Jeffrey Epstein, 
(dj) (Entered: 
03/25/2009) 
03/25/2009 
3 
F
ORDER OF PRETRIAL PROCEDURES. Signed by Senior Judge Kenneth 
L. Ryskamp on 3/25/2009. (sh) (Entered: 03/25/2009) 
03/26/2009 
4 
ORDER REASSIGNING CASE. Case reassigned to Judge Kenneth A. 
Marra for all further proceedings. Senior Judge Kenneth L. Ryskamp no 
longer assigned to case. Signed by Senior Judge Kenneth L. Ryskamp on 
3/24/2009. (cqs) (Entered: 03/26/2009) 
03/30/2009 
5 r 
Order Requiring Counsel to Confer and File Joint Scheduling Report. 
Signed by Judge Kenneth A. Marra on 3/30/2009. (ir) (Entered: 
03/30/2009) 
04/28/2009 
6 
7
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) 
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05/01/2009 
7 
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Defendant's MOTION for Extension of Time to File Response as to 1 
Complaint by Jeffrey Epstein. (Pike, Michael) (Entered: 05/01/2009) 
05/04/2009 
8 
ENDORSED ORDER granting 7 Motion for Extension of Time to Answer 
Complaint. Jeffrey Epstein response due 5/6/2009. Signed by Judge 
Kenneth A. Marra on 5/4/2009. (ir) (Entered: 05/04/2009) 
05/04/2009 
9 r MEMORANDUM in Opposition re ¢ Order to Show Cause by Jeffrey 
Epstein. (Pike, Michael) (Entered: 05/04/2009) 
05/05/2009 
10 
Clerks Notice of Docket Correction and Instruction to Filer re 9 
Memorandum in Opposition filed by Jeffrey Epstein. Error - Wrong Event 
Selected; Correct event "Response to ORder to Show Cause" In the future 
Please select the proper event. It is not necessary to refile this document. 
(tp) (Entered: 05/05/2009) 
05/05/2009 
11 
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MOTION for Leave to File Excess Pages by Jeffrey Epstein. (Critton, 
Robert) (Entered: 05/05/2009) 
05/06/2009 
12 
ENDORSED ORDER granting U Motion for Leave to File Excess Pages. 
Signed by Judge Kenneth A. Marra on 5/5/2009. (ir) (Entered: 05/06/2009) 
05/06/2009 
13 
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Defendant's MOTION to Dismiss 1 Complaint by Jeffrey Epstein. 
Responses due by 5/26/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B) 
(Pike, Michael) Modified on 5/7/2009 (Is). [Modified description of 
Attachment(s) from Motions to Dismiss to Exhibit A and Exhibit B] 
(Entered: 05/06/2009) 
05/14/2009 
Cases associated. (dg) (Entered: 05/14/2009) 
05/14/2009 
14 
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ORDER CONSOLIDATING CASES. Hereinafter all motions and other 
court filings that relate to discovery and all procedural motions that relate to 
multiple cases shall be styled with all of the case names and numbers and 
shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge 
Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM et 
al. (ir) (Entered: 05/14/2009) 
05/14/2009 
15 
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ORDER REQUESTING UNITED STATES PROVIDE POSITION TO 
MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009. 
(Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases: 
9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009) 
05/15/2009 
16 
11 
First MOTION for Extension of Time to File Response as to B Defendant's 
MOTION to Dismiss 1 ComplaintDefendant's MOTION to Dismiss 1 
Complaint by Jane Doe II. (Garcia, Isidro) (Entered: 05/15/2009) 
05/19/2009 
17 
ENDORSED ORDER denying as moot j Motion for Extension of Time to 
Respond to Motion to Dismiss. Plaintiffs response is due 5/26/09. Signed 
by Judge Kenneth A. Marra on 5/18/2009. (ir) (Entered: 05/19/2009) 
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Page 4 of 7 
05/20/2009 
18 
n 
NOTICE by 
of Filing Withdrawal of Previously Raised Objections 
to Defendant, Jeey Epstein's Motion to Compel And/Or Identify 
in the Style of This Case and Motion to Identify 
. in Third-Party 
Subpoenas for Purposes of Discovery, Or, Alternatively, Motion to Dismiss 
Sua Sponte, With Inorporated Memorandum of Law Associated Cases: 
9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 05/20/2009) 
05/20/2009 
19 
ORDER S
G in all Epstein cases EXCEPT case no. 08-80119: 
Notice by 
 of Filing Withdrawal of Previously Raised Objections to 
Epstein's Motion to Compel and/or Identify. This Notice should only be 
filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth 
A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-ICAM et al. (1c3) 
(Entered: 05/20/2009) 
05/22/2009 
20 
I-
RESPONSE in Opposition re 13 Defendant's MOTION to Dismiss 1 
ComplaintDefendant's MOTION to Dismiss 1 Complaint filed by Jane Doe 
II. (Garcia, Isidro) (Entered: 05/22/2009) 
05/27/2009 
21 
r 
NOTICE by Jane Doe re (111 in 9:08-cv-80119-KAM) Plaintiffs MOTION 
for Extension of Time to File Response as to (91 in 9:08-cv-80119-KAM) 
Defendant's MOTION to Compel Identity of Doe in Style of Case and 
Third-Party Subpoenas (replaces Docket entry 90)Plaintiffs MOTION for 
Extension of Time to File Response as to (91 in 9:08-cv-80119-KAM) 
Defendant's MOTION to Compel Identity of Doe in Style of Case and 
Third-Party Subpoenas (replaces Docket entry 90) (Attachments: # 1 Text 
of Proposed Order)Associated Cases: 9:08-cv-80119-KAM et al.(Horowitz, 
Adam) (Entered: 05/27/2009) 
05/28/2009 
22 
ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in 
case 08-80119. This Notice should only be filed in 08-80119, not in all of 
the Epstein cases... Signed by Judge Kenneth A. Marra on 5/28/2009. 
Associated Cases: 9:08-cv-80119-KAM et al. (Ic3) (Entered: 05/28/2009) 
05/29/2009 
23 
171 
NOTICE of Attorney Appearance by 
on behalf of 
iiiiiitrall
ica Associated Cases: 9:08-cv-80119-ICAM et al. 
, = 
(Entered: 05/29/2009) 
05/29/2009 24 
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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 
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Requesting Government's Position filed by United States of America. 
"Sue 
ly_
IM6/8/2009. Associated Cases: 9:08-cv-80119-ICAM et al. 
IM) (Entered: 05/29/2009) 
0x'29/2009 25 
r
RESPONSE in Opposition re (90 in 9:08-cv-80119-ICAM) Defendant's 
MOTION to Compel Identify Doe in Style of Case and in Third-Party 
Subpoenas, (91 in 9:08-cv-80119-KAM) Defendant's MOTION to Compel 
Identity of Doe in Style of Case and Third-Party Subpoenas (replaces 
Docket entry 90) filed by Jane Doe No. 102, Jane Doe No. 101. Associated 
Cases: 9:08-cv-80119-KAM et al.(Ezell, Katherine) (Entered: 05/29/2009) 
05/29/2009 26 
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-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-KAM, 
25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-
80656-KAM, 107 in 9:08-cv-80381-KAM) Response in Opposition to 
Motion, filed by Jane Doe No. 102, Jane Doe No. 101 DO NOT FILE IN 
EVERY EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES.. 
Signed by Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-
cv-80119-KAIVI et al. (1c3) (Entered: 05/29/2009) 
05/29/2009 
27 
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MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION 
TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, TO 
UNSEAL THE NONPROSECUTION AGREEMENT by Jane Doe No. 102, 
Jane Doe No. 101. Associated Cases: 9:08-cv-80119-KAM et al.(Ezell, 
Katherine) (Entered: 05/29/2009) 
05/29/2009 
28 
n 
MOTION TO RESCHEDULE HEARINGRescheduling Hearing or Appear 
By Telephone by Jane Doe No. 102, Jane Doe No. 101. Associated Cases: 
9:08-cv-80119-KAM et al.(Josefsberg, Robert) Modified on 6/1/2009 (tp). 
(Entered: 05/29/2009) 
06/01/2009 
29 
Clerks Notice of Docket Correction and Instruction to Filer re 28 Motion to 
Continue Hearing filed by Jane Doe No. 102, Jane Doe No. 101. The Filer 
selected the wrong motion relief(s) 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. (tp) 
(Entered: 06/01/2009) 
06/01/2009 30 
ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-ICAM, 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-ICAM, 
108 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv-
80380-KAM, 74 in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-KAM, 37 in 
9:09-cv-80591-KAM, 107 in 9:08-cv-80811-KAM, 27 in 9:09-cv-80469-
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• 
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 
31 
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REPLY to Response to Motion re 13 Defendant's MOTION to Dismiss I 
ComplaintDefendant's MOTION to Dismiss 1 Complaint filed by Jeffrey 
Epstein. (Pike, Michael) (Entered: 06/01/2009) 
06/04/2009 
32 
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REPLY to Response to Motion re (113 in 9:08-cv-80119-KAM) Plaintiffs 
MOTION Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-
Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply 
to Defendant Jeffrey Epstein's Response to Plaintiffs 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 
33 
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-KAM, 128 in 
9:08-cv-80380-ICAM, 65 in 9:08-cv-80994-KAM, 79 in 9:08-cv-80893-
KAM, 42 in 9:09-cv-80591-KAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09-
cv-80469-KAM, 79 in 9:08-cv-80993-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) 
06/08/2009 34 
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RESPONSE to Motion re (91 in 9:08-cv-80119-ICAM) Defendant's 
MOTION to Compel Identity of Doe in Style of Case and Third-Party 
Subpoenas (replaces Docket entry 90) filed by Jane Doe. 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 
35 
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NOTICE by Jane Doe re (113 in 9:08-cv-80119-KAM) Plaintiffs MOTION 
Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-Contact 
Order -Plaintiffs Jane Does 2-7 Notice of Joinder Associated Cases: 9:08-
cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
View Selected
or 
Download Selected 
PACER Service Center 
Transaction Receipt 
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06/10/2009 14:29:53 
PACER 
Login: 
du4480 
Client Code: 
Description: 
Docket 
Report 
Search 
Criteria: 
9:09-cv-80469-
ICAM 
Billable 
Pages: 
4 
Cost: 
0.32 
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U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE #: 9:09-cv-80591-KAM 
Doe No. 101 v. Epstein 
Assigned to: Judge Kenneth A. Marra 
Lead case: 9:08-cv-80119-ICAM 
Member case: (View Member Case) 
Cause: 28:1331 Fed. Question: Personal Injury 
Plaintiff 
Jane Doe No. 101 
V. 
Defendant 
Jeffrey Epstein 
Date Filed: 04/17/2009 
Jury Demand: Plaintiff 
Nature of Suit: 360 P.I.: Other 
Jurisdiction: Federal Question 
represented by Katherine Warthen Ezell 
Podhurst Orseck Josefsberg et al 
City National Bank Building 
25 W Flagler Street 
Suite 800 
Miami FL 33130-1780 
Fax: 
Email: [email protected] 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Robert,. Josefsberg 
Podhurst Orseck Josefsberg et al 
City National Bank Building 
25 W Flagler Street 
Suite 800 
Miami FL 33130-1780 
Fax: 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
represented by Michael James Pike 
Burman Critton Luttier & Coleman 
LRJ 
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515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Fax: 515-3148 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Robert Deweese Critton , Jr. 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Amiens 
United States of America 
represented by 
Fax: 
Email: [email protected] 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Jay P. Leikowitz 
Kirkland & Ellis 
655 15th Street NW 
Suite 1200 
Washin on DC 20005 
Email: 
PRO HAC VICE 
ATTORNEY TO BE NOTICED 
Michael D. Shumsky 
Kirkland & Ellis 
655 15th Street NW 
Suite 1200 
hin on DC 20005 
Email: michael.shumsky®ldrldand.com 
PRO HAC VICE 
ATTORNEY TO BE NOTICED 
United States Attorney's Office 
500 East Broward Blvd 
https://ecf.flsd.uscourts.govicgi-binMktRpt.p17716393569552562-L_801_0-1 
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Page 3 of 9 
7th Floor 
Ft Lauderdale , FL 33394 
ext. 3546 
Fax: 356-7336 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Date Filed 
# clear Docket Text 
04/17/2009 
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COMPLAINT and Demand for Jury Trial against Jeffrey Epstein. Filing 
fee $ 350.00. Receipt#: 999318, filed by Jane Doe No. 101.(asl) (Entered: 
04/20/2009) 
04/17/2009 
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Summons Issued as to Jeffrey Epstein. (as!) (Entered: 04/20/2009) 
04/17/2009 
3 
Sealed Document. (igo) (Entered: 04/20/2009) 
04/17/2009 
4 
Sealed Document. (igo) (Entered: 04/20/2009) 
04/21/2009 
5_ 
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Order Requiring Counsel to Confer and File Joint Scheduling Report. 
Signed by Judge Kenneth A. Marra on 4/21/2009. (ir) (Entered: 
04/21/2009) 
04/28/2009 
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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) 
05/01/2009 
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First AMENDED COMPLAINT and Demand for Jury Trial, filed by Jane 
Doe No. 101.(Ezell, Katherine) (Entered: 05/01/2009) 
05/01/2009 
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RESPONSE TO ORDER TO SHOW CAUSE by Jane Doe No. 101. (Ezell, 
Katherine) (Entered: 05/01/2009) 
05/01/2009 
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First AMENDED COMPLAINT and Demand For Jury Trial, filed by Jane 
Doe No. 101.(Ezell, Katherine) (Entered: 05/01/2009) 
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NOTICE of Striking 7 Amended Complaint filed by Jane Doe No. 101 by 
Jane Doe No. 101 (Ezell, Katherine) Modified on 5/6/2009 (1s). (Entered: 
05/04/2009) 
05/04/2009 
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Defendant's MOTION for Extension of Time to File Response as to 9 
Amended Complaint by Jeffrey Epstein. (Pike, Michael) (Entered: 
05/04/2009) 
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MEMORANDUM in Opposition re 6 Order to Show Cause by Jeffrey 
Epstein. (Pike, Michael) (Entered: 05/04/2009) 
05/05/2009 
13 
ENDORSED ORDER granting 11 Motion for Extension of Time to 
Answer Complaint. Jeffrey Epstein response due 5/26/2009. Signed by 
Judge Kenneth A. Marra on 5/5/2009. (ir) (Entered: 05/05/2009) 
05/06/2009 
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NOTICE by Jane Doe No. 101 Notice of Filing (Attachments: # 1 Motion 
to Proceed Anonymously and Incorporated Memorandum of Law)(Ezell, 
Katherine) (Entered: 05/06/2009) 
05/07/2009 
15 
17 
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NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf 
of Jeffrey Epstein (Critton, Robert) (Entered: 05/07/2009) 
05/11/2009 
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RESPONSE/REPLY to 14 Notice (Other) Opposition to Motion to Proceed 
Anonymously by Jeffrey Epstein. (Critton, Robert) (Entered: 05/11/2009) 
05/11/2009 
17 
MOTION to Compel and/or identifr Jane doe #101 in the style of this case 
and motion to identifr Jane doe #101 in the third party subpoenas for 
purposes of discovery with incorporated memorandum of law by Jeffrey 
Epstein. Responses due by 5/29/2009 (see docket entry 16 for imageXtas) 
(Entered: 05/12/2009) 
05/14/2009 
Cases associated. (dg) (Entered: 05/14/2009) 
05/14/2009 
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ORDER CONSOLIDATING CASES. Hereinafter all motions and other 
court filings that relate to discovery and all procedural motions that relate 
to multiple cases shall be styled with all of the case names and numbers and 
shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge 
Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM et 
al. (ir) (Entered: 05/14/2009) 
05/14/2009 12 
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ORDER REQUESTING UNITED STATES PROVIDE POSITION TO 
MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009. 
(Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases: 
9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009) 
05/14/2009 
20 
ORDER terminating 17 Motion to Compel. See Order consolidating cases. 
See procedural motions pending: DE 91 in 08-80119.. Signed by Judge 
Kenneth A. Marra on 5/14/2009. (1c3) (Entered: 05/14/2009) 
05/18/2009 
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Defendant's MOTION for Leave to File Excess Pages on Defendant's 
Motion to Dismiss First Amended Complaint by Jeffrey Epstein. (Pike, 
Michael) (Entered: 05/18/2009) 
05/19/2009 
22 
ENDORSED ORDER granting 21 Motion for Leave to File Excess Pages. 
Signed by Judge Kenneth A. Marra on 5/19/2009. (ir) (Entered: 
05/19/2009) 
hnps://cciflsd.uscourts.gov/cgi-bin/DktRpt.p17716393569552562-L_801_0-1 
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05/20/2009 
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NOTICE by 
. of Filing Withdrawal of Previously Raised Objections 
to Defendant, Jeffrey Epstein's Motion to Compel And/Or 'den* 
. 
in the Style of This Case and Motion to Identift 
. in Third-Party 
Subpoenas for Purposes of Discovery, Or, Alternatively, Motion to Dismiss 
Sua Sponte, With Inorporated Memorandum of Law Associated Cases: 
9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 05/20/2009) 
05/20/2009 
24 
ORDER STRIKING in all Epstein cases EXCEPT case no. 08-80119: 
Notice by 
. of Filing Withdrawal of Previously Raised Objections to 
Epstein's Motion to Compel and/or Identify. This Notice should only be 
filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth 
A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-KAM et al. (1c3) 
(Entered: 05/20/2009) 
05/21/2009 
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MOTION for Leave to Appear Limited Appearance Pro Hac Vice by 
Jeffrey Epstein. Responses due by 6/8/2009 (Attachments: # 1 Certification 
Certification of Jay P. Leflcowitz, # 2 Text of Proposed Order Proposed 
Order Granting Motion for Limited Appearance of Jay P. Lefkowitz) 
(Critton, Robert) (Entered: 05/21/2009) 
05/21/2009 26 
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MOTION for Leave to Appear Limited Appearance Pro Hac Vice by 
Jeffrey Epstein. Responses due by 6/8/2009 (Attachments: # 1 Certification 
of Shtunsky, # 2 Text of Proposed Order Granting Motion for Limited 
Appearance of Michael D. Shumsky)(Critton, Robert) (Entered: 
05/21/2009) 
05/26/2009 
27 
Clerks Notice of Instruction to Filer Regarding Pro Hac Vice Motion. 
Pursuant to 2B in the Administrative Procedures, a motion to make a 
limited appearance must be filed in the conventional manner along with the 
applicable filing fee. LOCAL COUNSEL IS INSTRUCTED TO 1. FILE A 
NOTICE TO STRIKE DE# 26 MOTION for Leave to Appear Limited 
Appearance Pro Hac Vice filed by Jeffrey Epstein, 25 MOTION for Leave 
to Appear Limited Appearance Pro Hac Vice filed by Jeffrey Epstein AND 
2. CONVENTIONALLY FILE AN ORIGINAL MOTION TO MAKE A 
LIMITED APPEARANCE ALONG WITH THE APPLICABLE FILING 
FEE. (1s) (Entered: 05/26/2009) 
05/26/2009 28 
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Plaintiffs MOTION to Preserve Evidence Plaintiffs Jane Doe No. 101 and 
Jane Doe No. 102's Motion for an Order for the Preservation of Evidence 
and Incorporated Memorandum of Law by Jane Doe No. 101, Jane Doe 
No. 102. (Attachments: # 1 Exhibit "A", # 2 Exhibit "B", # 3. Text of 
Proposed Order)Associated Cases: 9:08-cv-80119-KAM, 9:09-cv-80591-
KAM, 9:09-cv-80656-KAM(Ezell, Katherine) (Entered: 05/26/2009) 
05/26/2009 
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Defendant's MOTION to Dismiss 7 Amended Complaint or in the 
Alternative, for a More Definate Statement by Jeffrey Epstein. Responses 
due by 6/12/2009 (Attachments: # 1 Exhibit "A", # 2 Exhibit "B"XCritton, 
Robert) (Entered: 05/26/2009) 
https://ecf.flscLuscourts.gov/cgi-bin/DktRpt.p17716393569552562-L_801_0-1 
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05/27/2009 30 
ORDER terminating(28) Motion to Preserve Evidence in case 9:09-cv-
80591-ICAM; terminating(16) Motion to Preserve Evidence in case 9:09-
cv-80656-KAM This motion is pending ONLY in case no. 08-80119.. 
Signed by Judge Kenneth A. Marra on 5/27/2009. (1c3) (Entered: 
05/27/2009) 
05/27/2009 
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NOTICE by Jane Doe re (111 in 9:08-cv-80119-ICAM) Plaintiffs 
MOTION for Extension of Time to File Response as to (91 in 9:08-cv-
80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of 
Case and Third-Party Subpoenas (replaces Docket entry 90)Plaintiffs 
MOTION for Extension of Time to File Response as to (91 in 9:08-cv-
80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of 
Case and Third-Party Subpoenas (replaces Docket entry 90) (Attachments: 
# 1 Text of Proposed Order)Associated Cases: 9:08-cv-80119-ICAM et al. 
(Horowitz, Adam) (Entered: 05/27/2009) 
05/28/2009 
32 
ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in 
case 08-80119. This Notice should only be filed in 08-80119, not in all of 
the Epstein cases... Signed by Judge Kenneth A. Marra on 5/28/2009. 
Associated Cases: 9:08-cv-80119-ICAM et al. (1c3) (Entered: 05/28/2009) 
05/29/2009 
33 
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NOTICE of Attorney Appearance by 
. 
on behalf of 
United States of America Associated Cases: 9:08-cv-80119-ICAM et al. 
l:
, 
n 
(Entered: 05/29/2009) 
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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-ICAM) Defendant's 
MOTION to Stay re (56) Amended Complaint, (68 in 9:08-cv-80381-
KAM) Defendant's MOTION to Stay re (60) Amended Complaint, (51 in 
9:08-cv-80811-KAM) Defendant's MOTION to Stay re (40) Amended 
Complaint and or Continue Action Filed Pursuant to Court's Order 
Requesting Government's Position filed by United States of America. 
liS
luelL6/8/2009. Associated Cases: 9:08-cv-80119-ICAM et al. 
MM) 
(Entered: 05/29/2009) 
05/29/2009 35 
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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-ICAM et al.(Ezell, Katherine) (Entered: 05/29/2009) 
05/29/2009 36 
ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
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KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-ICAM, 106 in 9:08-
cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-KAM, 
25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-
80656-KAM, 107 in 9:08-cv-80381-KAM) Response in Opposition to 
Motion, filed by Jane Doe No. 102, Jane Doe No. 101 DO NOT FILE IN 
EVERY EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES.. 
Signed by Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-
cv-80119-ICAM et al. (1c3) (Entered: 05/29/2009) 
05/29/2009 37 
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MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION 
TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, TO 
UNSEAL THE NONPROSECUTION AGREEMENT by Jane Doe No. 102, 
Jane Doe No. 101. Associated Cases: 9:08-cv-80119-KAM et al.(Ezell, 
Katherine) (Entered: 05/29/2009) 
05/29/2009 
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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 
39 
ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-KAM, 77 in 9:08-
cv-80993-KAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-KAM, 
63 in 9:08-cv-80994-KAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv-
80811-KAM) Motion to Continue Hearing filed by Jane Doe No. 102, Jane 
Doe No. 101, (76 in 9:08-cv-80993-KAM, 109 in 9:08-cv-80381-KAM, 
108 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv-
80380-ICAM, 74 in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-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) 
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MOTION for Limited Appearance, Consent to Designation and Request to 
Electronically Receive Notices of Electronic Filings for Michael D. 
Shumsky, Filing Fee $75.00, Receipt #725905. (ow) (Entered: 06/04/2009) 
06/04/2009 
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MOTION for Limited Appearance, Consent to Designation and Request to 
Electronically Receive Notices of Electronic Filings for Jay P. Lefkowitz, 
Filing Fee $75.00, Receipt #725904. (cw) (Entered: 06/04/2009) 
06/04/2009 
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REPLY to Response to Motion re (113 in 9:08-cv-80119-KAM) Plaintiffs 
MOTION Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-
Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply 
to Defendant Jeffrey Epstein's Response to Plaintiffi 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) 
https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p17716393569552562-L 801_0-1 
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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-KAM, 128 in 
9:08-cv-80380-KAM, 65 in 9:08-cv-80994-KAM, 79 in 9:08-cv-80893-
KAM, 42 in 9:09-cv-80591-KAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09-
cv-80469-KAM, 79 in 9:08-cv-80993-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) 
06/07/2009 
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54 A 
ORDER granting 40 Motion for Limited Appearance, Consent to 
Designation and Request to Electronically Receive Notices of Electronic 
Filings. Signed by Judge Kenneth A. Marra on 6/7/2009. (ail) (Entered: 
06/09/2009) 
06/08/2009 
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RESPONSE to Motion re (91 in 9:08-cv-80119-ICAM) Defendant's 
MOTION to Compel Identity of Doe in Style of Case and Third-Party 
Subpoenas (replaces Docket entry 90) filed by Jane Doe. 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 
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NOTICE by Jane Doe re (113 in 9:08-cv-80119-KAM) Plaintiffs 
MOTION Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-
Contact Order :Plaintiffs Jane Does 2-7 Notice of Joinder Associated 
Cases: 9:08-cv-80119-ICAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/08/2009 
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ORDER granting 41. Motion for Limited Appearance, Consent to 
Designation and Request to Electronically Receive Notices of Electronic 
Filings. Signed by Judge Kenneth A. Marra on 6/8/2009. (ail) (Entered: 
06/09/2009) 
06/09/2009 
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Plaintiffs MOTION for Extension of Time to File Response as to 29 
Defendant's MOTION to Dismiss 7 Amended Complaint or in the 
Alternative, for a More Definate StatementDefendant's MOTION to 
Dismiss 7 Amended Complaint or in the Alternative, for a More Definate 
Statement Plaintiff Jane Doe No. 10I's Motion for Enlargement of Time 
and Page Limits for Response to Defendant's Motion to Dismiss the First 
Amended Complaint or, in the Alternative, for a More Definite Statement 
by Jane Doe No. 101. (Attachments: # 1 Text of Proposed OrderXEzell, 
Katherine) (Entered: 06/09/2009) 
06/09/2009 
51 
MOTION for Leave to File Excess Pages by Jane Doe No. 101. SEE 
IMAGE 48 (ail) (Entered: 06/10/2009) 
06/10/2009 
49 
ENDORSED ORDER granting 48 Motion for Extension of Time to 
Respond re 29 Defendant's MOTION to Dismiss 7 Amended Complaint or 
https://ecf.flsd.uscourts.gov/egi-bin/DktRpt.pl?716393569552562-L_801_0-1 
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