EFTA00175775

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U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE #: 9:08-cv-80380-KAM 
Doe No. 4'. Epstein 
Assigned to: Judge Kenneth A. Marra 
Referred to: Magistrate Judge Linnea R. Johnson 
Lead case: 9:08-ev-80111-.KAM
Member case• (View Member Case) 
Case: 9:09-0-80802-KAM 
Cause: 28:1332 Diversity 
Plaintiff 
Jane Doe No. 4 
Date Filed: 04/14/2008 
Jury Demand: Plaintiff 
Nature of Suit: 360 P.I.: Other 
Jurisdiction: Diversity 
represented by Adam D. Horowitz 
Mermelstein & Horowitz PA 
18205 Biscayne Boulevard 
Suite 2218 
Miami FL 33160 
Fax: 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Jeffrey Marc Herman 
Herman & Mermelstein 
18205 Biscayne Boulevard 
Suite 2218 
Miami FL 33160 
Fax: 931-0877 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Stuart S. Mermelstein 
Mermelstein & Horowitz PA 
18205 Biscayne Boulevard 
Suite 2218 
Miami FL 33160 
MOM 
Fax: 931-0877 
Email: 
LRJ 
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LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Defendant 
Jeffrey Epstein 
represented by Jeffrey Epstein 
9 East 71st Street 
New York, NY 10021 
PRO SE 
Jack Alan Goldberger 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach , FL 33401-5012 
Fax: 835-8691 
Email: 
ATTORNEY TO BE NOTICED 
Michael James Pike 
Burman Critton Luther & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach, FL 33401-2918 
Fax: 515-3148 
Email: 
ATTORNEY TO BE NOTICED 
Michael Ross Tein 
Lewis Tein 
3059 Grand Avenue 
Suite 340 
Coconut Grove , FL 33133 
Fax: 442-6744 
Email: 
ATTORNEY TO BE NOTICED 
Robert Deweese Critton , Jr. 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Fax: 
Email: 
ATTORNEY TO BE NOTICED 
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Auto 
United States of America 
represented by. 
United States Attorney's Office 
500 East Broward Blvd 
7th Floor 
Ft Lauderdale , FL 33394 
ext. 3546 
Fax: 35111
1 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Date Filed 
# 
Docket Text 
04/14/2008 
1 COMPLAINT against Jeffrey Epstein Filing fee $ 350. Receipt#: 542769, 
filed by Jane Doe No. 4.(dj) (Entered: 04/14/2008) 
04/14/2008 
2 Summons Issued as to Jeffrey Epstein. (dj) (Entered: 04/14/2008) 
04/17/2008 
3 ORDER OF TRANSFER. Case reassigned to Judge Kenneth A. Marra for all 
further proceedings. Judge Daniel T. K. Hurley no longer assigned to 
caseSigned by Judge Daniel T. K. Hurley on 4/15/08.(ail) (Entered: 
04/17/2008) 
04/18/2008 
4 ORDER REFERRING CASE to Magistrate Judge Linnea R. Johnson. 
Magistrate Judge James M. Hopkins no longer assigned as referral judge in 
case.Signed by Magistrate Judge James M. Hopkins on 4/18/08.(lw) Modified 
on 4/23/2008 (1w). (Entered: 04/18/2008) 
04/21/2008 
5 Order Requiring Counsel to Confer and File Joint Scheduling Report.Signed 
by Judge Kenneth A. Marra on 4/18/08.(ir) (Entered: 04/21/2008) 
05/22/2008 
6 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey 
Epstein on May 7, 2008, filed by Jane Doe No. 4. (Herman, Jeffrey) (Entered: 
05/22/2008) 
05/29/2008 
7. Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane 
Doe No. 4. (Attachments: # 1 Exhibit A and B, # 2 Text of Proposed Order 
Default OrderXHorowitz, Adam) (Entered: 05/29/2008) 
06/02/2008 
$ Clerks Entry of Default as to Jeffrey Epstein terminated 7 Motion for Entry of 
Default by Clerk (ail) (Entered: 06/02/2008) 
06/05/2008 
2 Plaintiffs MOTION for Judgment Upon Default and Order Setting Hearing 
on Damagers by Jane Doe No. 4. (Attachments: # 1 Text of Proposed Order) 
(Horowitz, Adam) (Entered: 06/05/2008) 
06/13/2008 
1.0 NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of 
Jeffrey Epstein (Goldberger, Jack) (Entered: 06/13/2008) 
06/13/2008 
11 MOTION to Set Aside Default by Jeffrey Epstein. (Attachments: # I Affidavit 
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of Richard Bamett)(Goldberger, Jack) (Entered: 06/13/2008) 
06/19/2008 
12 RESPONSE in Opposition re 2 Plaintiffs MOTION for Judgment Upon 
Default and Order Setting Hearing on Damagers (DE #9) filed by Jeffrey 
Epstein. (Goldberger, Jack) (Entered: 06/19/2008) 
06/20/2008 
B Defendant's MOTION to Stay by Jeffrey Epstein. Responses due by 7/10/2008 
(Goldberger, Jack) (Entered: 06/20/2008) 
06/20/2008 
14 Defendant's MOTION for Extension of Time to File Answer or Otherwise 
Respond To Complaint by Jeffrey Epstein. (Goldberger, Jack) (Entered: 
06/20/2008) 
06/25/2008 
15 MEMORANDUM in Support re 7 Plaintiffs MOTION for Entry of Default 
by Clerk Against Defendant filed by Jane Doe No. 4. (Herman, Jeffrey) 
(Entered: 06/25/2008) 
06/25/2008 
16 RESPONSE to Motion re 11 MOTION to Set Aside Default filed by Jane Doe 
No. 4. Replies due by 7/7/2008. (Herman, Jeffrey) (Entered: 06/25/2008) 
07/01/2008 
17 NOTICE by Jeffrey Epstein Concerning Motion To Stay [DE 13) 
(Attachments: # 1 Exhibit "A" Final Disposition Sheets)(Goldberger, Jack) 
(Entered: 07/01/2008) 
07/07/2008 
111 NOTICE of Attorney Appearance by Michael Ross Tein on behalf of Jeffrey 
Epstein (Tein, Michael) (Entered: 07/07/2008) 
07/07/2008 
1.9 MOTION Epstein's Reply in Support of Motion [DE11] to Set Aside Clerk's 
Default by Jeffrey Epstein. (rein, Michael) (Entered: 07/07/2008) 
07/08/2008 
2,0 RESPONSE in Support re H MOTION to Set Aside Default filed by Jeffrey 
Epstein. (Goldberger, Jack) (Entered: 07/08/2008) 
07/08/2008 
21 NOTICE by Jeffrey Epstein re 2Q Response in Support of Motion [DE 11] To 
Set Aside Clerk's Default. (Goldberger, Jack) (Entered: 07/08/2008) 
07/08/2008 
22 NOTICE of Instruction to Filer: re 19 MOTION Epstein's Reply in Support of 
Motion [DE11] to Set Aside Clerk's Default filed by Jeffrey Epstein Error: 
Wrong Event Selected; Instruction to Filer: Counsel is instructed to re-file 
document using the correct event REPLY TO RESPONSE TO MOTION; In 
the future please select the proper event. (dg) (Entered: 07/08/2008) 
07/08/2008 
23 REPLY to Response to Motion re _a MOTION to Set Aside Default, 19 
MOTION Epstein's Reply in Support of Motion [DE11] to Set Aside Clerk's 
Default Epstein's Reply in Support of Motion [DE11] to Set Aside Clerk's 
Default filed by Jeffrey Epstein. (rein, Michael) (Entered: 07/08/2008) 
07/10/2008 
24 Plaintiffs MOTION for Extension of Time to File Response as to la 
Defendant's MOTION to Stay by Jane Doe No. 4. (Attachments: # 1 Text of 
Proposed Order)(Horowitz, Adam) (Entered: 07/10/2008) 
07/10/2008 
25 Sealed Document. (yc) UNSEALED see DE 22 . Modified on 7/17/2008 (bs). 
(Entered: 07/10/2008) 
07/10/2008 
26 Sealed Document. (ye) UNSEALED see DE IQ . Modified on 7/17/2008 (bs). 
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(Entered: 07/10/2008) 
07/10/2008 
22 UNSEALED MOTION to Seal by Jeffrey Epstein. (previously filed as 25 
sealed document) (bs) (Entered: 07/17/2008) 
07/10/2008 
12 UNSEALED Notice of Continued Pendency of Federal Criminal Action by 
Jeffrey Epstein (previously filed as 26 sealed document) (bs) (Entered: 
07/17/2008) 
07/16/2008 
22 ORDER denying motion to file Ex Parte and Under Seal. The clerk shall 
unseal DE 25 and 26 and make them available for public inspection through 
CM/ECF at the earliest possible time. Signed by Judge Kenneth A. Marra on 
7/16/08. (ir) (Additional attachment(s) added on 7/17/2008: # I Docket Sheet) 
(bs). (Entered: 07/16/2008) 
07/16/2008 
28 ORDER denying without prejudice ll Motion to Set Aside Default. The 
Defendant has ten days to file a second motion to vacate the default. Signed 
by Judge Kenneth A. Marra on 7/16/08. (ir) (Entered: 07/16/2008) 
07/18/2008 
31 RESPONSE to Motion re 13 Defendant's MOTION to Stay and Memorandum 
of Law filed by Jane Doe No. 4. Replies due by 7/28/2008. (Attachments: # 1 
Exhibit A)(Herman, Jeffrey) (Entered: 07/18/2008) 
07/21/2008 
32 AFFIDAVIT signed by : Jeffrey M. Herman. Regarding Service of Process 
and This Court's Order to Show Cause by Jane Doe No. 4. (Herman, Jeffrey) 
(Entered: 07/21/2008) 
07/25/2008 
32 MOTION for Hearing Defendant's Request for Oral Argument by Jeffrey 
Epstein. (Tein, Michael) (Entered: 07/25/2008) 
07/25/2008 
3±1 ORDER granting Ii. MOTION to Set Aside Default filed by Jeffrey Epstein. 
The Clerk's entry of Default DE a is vacated. The Court's Order DE a of July 
16, 2008 is vacated. Signed by Judge Kenneth A. Marra on 7/25/08. (ir) 
(Entered: 07/25/2008) 
07/28/2008 
35 UNSEALED Sealed Document. (tas) Modified on 8/12/2008 "Please see DE 
# 41 for Image" (gp). (Entered: 07/28/2008) 
07/28/2008 
36 UNSEALED Sealed Document. (tas) Modified on 8/12/2008 "Please see DE 
# 44 for Image** (gp). (Entered: 07/28/2008) 
07/28/2008 
43 UNSEALED MOTION for Leave to File by Jeffrey Epstein. (Originally DE # 
35 } (gp) (Entered: 08/12/2008) 
07/28/2008 
44 UNSEALED REPLY to Response to Motion re 13 Defendant's MOTION to 
Stay filed by Jeffrey Epstein. (Originally DE # 36 } (gp) (Entered: 
08/12/2008) 
07/29/2008 
17 NOTICE by Jeffrey Epstein Defendant's Notice of Filing Exhibits 
(Attachments: # 1 Exhibit A, # 2 Exhibit BXTein, Michael) (Entered: 
07/29/2008) 
07/30/2008 
a NOTICE by Jeffrey Epstein Waiver of Service (rein, Michael) (Entered: 
07/30/2008) 
. 
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08/05/2008 
39 ORDER denying 13 Motion to Stay; granting nuns pro tune 24 Motion for 
Extension of Time to Respond ; denying as moot 31 Motion for Hearing. 
Signed by Judge Kenneth A. Marra on 8/4/08. (ir) (Entered: 08/05/2008) 
08/05/2008 
40 ORDER DENYING MOTION TO SEAL. The Clerk shall unseal DE 36 
Sealed Document, 35 Sealed Document and make them available for public 
inspection through CM/ECF. Signed by Judge Kenneth A. Marra on 8/4/08. 
(ir) (Entered: 08/05/2008) 
08/06/2008 
41 Joint MOTION to Approve Stipulation for Acceptance of Service of Process 
and Agreed Date For Defendant's Responses to Complaints by Jane Doe No. 
4. (Attachments: # 1 Stipulation, # 2 Text of Proposed Order Approving 
Stipulation)(Herman, Jeffrey) (Entered: 08/06/2008) 
08/07/2008 
42 ENDORSED ORDER granting 41 Motion to Approve Stipulation for 
Acceptance of Service of Process and Agreed Date For Defendant's Responses 
to Complaints. Signed by Judge Kenneth A. Marra on 8/6/08. (ir) (Entered: 
08/07/2008) 
08/07/2008 
Reset Answer Due Deadline: Jeffrey Epstein response due 9/4/2008. (ir) 
(Entered: 08/07/2008) 
08/27/2008 
45 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 45 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 
46 NOTICE of Attorney Appearance by Michael James Pike, Robert Deweese 
Critton, Jr on behalf of Jeffrey Epstein (ail) (Entered: 08/28/2008) 
09/04/2008 
42 Defendant's MOTION to Dismiss 1 Complaint by Jeffrey Epstein. Responses 
due by 9/22/2008 (Tein, Michael) (Entered: 09/04/2008) 
09/22/2008 
41 MEMORANDUM in Opposition re 42 Defendant's MOTION to Dismiss 1 
Complaint filed by Jane Doe No. 4. (Herman, Jeffrey) (Entered: 09/22/2008) 
09/22/2008 
49 AMENDED COMPLAINT, filed by Jane Doe No. 4.(Herman, Jeffrey) 
(Entered: 09/22/2008) 
09/23/2008 
50 ENDORSED ORDER denying as moot 2 Motion for Judgment upon Default. 
Clerk's entry of default vacated on 7/25/08. See DE 14 . Signed by Judge 
Kenneth A. Matra on 9/23/08. (ir) (Entered: 09/23/2008) 
09/23/2008 
51 ORDER denying as moot 42 Motion to Dismiss; denying as moot 14 Motion 
for Extension of Time to Respond to Complaint. Signed by Judge Kenneth A. 
Marra on 9/23/08. (ir) (Entered: 09/23/2008) 
09/25/2008 
52 SCHEDULING REPORT- Rule 26(1). (Herman, Jeffrey) (Entered: 
09/25/2008) 
09/30/2008 
53 SCHEDULING ORDER: Jury Trial set for 1/25/2010 09:00 AM in West 
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Palm Beach Division before Judge Kenneth A. Marra. Calendar Call set for 
1/22/201010:00 AM in West Palm Beach Division before Judge Kenneth A. 
Marra., Amended Pleadings due by 12/1/2008. Discovery due by 8/3/2009. 
Motions due by 8/31/2009. ORDER REFERRING CASE to Magistrate Judge 
Linnea R. Johnson for Discovery Proceedings, ORDER REFERRING CASE 
to Mediation. 15 days to appoint mediator. Signed by Judge Kenneth A. Marra 
on 9/29/08. (ir) (Entered: 09/30/2008) 
10/06/2008 
54 Defendant's MOTION to Dismiss 42 Amended Complaint and for More 
Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Critton, 
Robert) (Entered: 10/06/2008) 
10/24/2008 
55 Unopposed MOTION for Extension of Time to File Response as to 54 
Defendant's MOTION to Dismiss 42 Amended Complaint and for More 
Definite Statement by Jane Doe No. 4. (Attachments: # 1 Text of Proposed 
Order)(Herman, Jeffrey) (Entered: 10/24/2008) 
10/27/2008 
5.6 ORDER granting (47 in 9:08-cv-80119-KAM) Unopposed MOTION for 
Extension of Time to File Response as to (46) Defendant's MOTION to 
Dismiss (42) Amended Complaint and for More Definite Statement 
( Responses due by 10/31/2008) in case 9:08-cv-80119-ICAM; granting (43) 
Motion for Extension of Time to Respond re (47 in 9:08-cv-80119-ICAM) 
Unopposed MOTION for Extension of Time to File Response as to (46) 
Defendant's MOTION to Dismiss (42) Amended Complaint and for More 
Definite Statement in case 9:08-cv-80232-KAM; granting (55) Motion for 
Extension of Time to Respond re (47 in 9:08-cv-80119-KAM) Unopposed 
MOTION for Extension of Time to File Response as to (46) Defendant's 
MOTION to Dismiss (42) Amended Complaint and for More Definite 
Statement incase 9:08-cv-80380-KAM; granting (53) Motion for Extension of 
Time to Respond re (47 in 9:08-cv-80119-1CAM) Unopposed MOTION for 
Extension of Time to File Response as to (46) Defendant's MOTION to 
Dismiss (42) Amended Complaint and for More Definite Statement in case 
9:08-cv-80381-ICAM in case 9:08-cv-80119-KAM. Signed by Judge Kenneth 
A. Marra on 10/24/2008. (ir) (Entered: 10/27/2008) 
10/28/20(1 S 
Reset Deadlines as to Defendant's MOTION to Dismiss (49) Amended 
Complaint and for More Definite Statement. Responses due by 10/31/2008. 
(ir) (Entered: 10/28/2008) 
10/31/2008 
• 
52 MEMORANDUM in Opposition re 54 Defendant's MOTION to Dismiss 42 
Amended Complaint and for More Definite Statement filed by Jane Doe No. 
4. (Attachments: # I_ Exhibit A)(Herman, Jeffrey) (Entered: 10/31/2008) 
11/10/2008 
5$1 RESPONSE/REPLY to 52 Memorandum in Opposition to Defendant's Motion 
to Dismiss filed by Jeffrey Epstein. (Critton, Robert) (Entered: 11/10/2008) 
12/30/2008 
52 NOTICE by Jeffrey Epstein of Withdrawal as Co-Counsel (Tein, Michael) 
(Entered: 12/30/2008) 
02/12/2009 
6.0 OPINION AND ORDER granting in part and denying in part 54 Motion to 
Dismiss and Motion for More Definite Statement. Signed by Judge Kenneth 
A. Marra on 2/12/2009. (ir) (Entered: 02/12/2009) 
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02/23/2009 
61 NOTICE by Jane Doe No. 4 of Change of Name of Plaintiffs Counsel 
(Horowitz, Adam) (Entered: 02/23/2009) 
02/27/2009 
52 AMENDED COMPLAINT (Second), filed by Jane Doe No. 4.(Horowitz, 
Adam) (Entered: 02/27/2009) 
03/02/2009 
62 Plaintiffs MOTION to Compel Answers to Interrogatories and Production of 
Documents and Incorporated Memorandum of Law in Support by Jane Doe 
No. 4. Responses due by 3/19/2009 (Attachments: # I Exhibit A, # 2 Exhibit 
B)(Horowitz, Adam) (Entered: 03/02/2009) 
03/04/2009 
M Defendant's MOTION for Extension of Time to File Response as to 62 
Amended Complaint with proposed Order by Jeffrey Epstein. (Critton, 
Robert) (Entered: 03/04/2009) 
03/05/2009 
65 ENDORSED ORDER granting 64 Motion for Extension of Time to Answer 
Complaint. Jeffrey Epstein response due 4/3/2009. Signed by Judge Kenneth 
A. Marra on 3/5/2009. (ir) (Entered: 03/05/2009) 
03/06/2009 
56 Defendant's MOTION for Extension of Time to File Response as to 62 
Plaintiffs MOTION to Compel Answers to Interrogatories and Production of 
Documents and Incorporated Memorandum of Law in Support with proposed 
Order by Jeffrey Epstein. (Critton, Robert) (Entered: 03/06/2009) 
03/12/2009 
6/ ORDER granting 56 Motion for Extension of Time to Respond re 61 
Plaintiffs MOTION to Compel Answers to Interrogatories and Production of 
Documents and Incorporated Memorandum of Law in Support. Responses due 
by 3/25/2009. Signed by Magistrate Judge Linnea R. Johnson on 3/12/2009. 
(kza) (Entered: 03/13/2009) 
03/18/2009 
5B. Defendant's MOTION for Leave to File Excess Pages with proposed Order in 
Response to 62 Motion to Compel Answers and Interrogatories and 
Production of Documents, Including Supporting Memorandum of Law by 
Jeffrey Epstein. (Critton, Robert) Modified link and text on 3/19/2009 (tas). 
(Entered: 03/18/2009) 
03/19/2009 
69 Clerks Notice of Docket Correction and Instruction to Filer re 61 Defendant's 
MOTION for Leave to File Excess Pages with proposed Order filed by Jeffrey 
Epstein. Error - Incorrect Document Link/No Link; Correction - Document 
relinked properly by Clerk. Instruction to filer - In the future, please link the 
document to the proper entry. It is not necessary to refile this document. (tas) 
(Entered: 03/19/2009) 
03/25/2009 
ZQ RESPONSE to Motion re 62 Plaintiffs MOTION to Compel Answers to 
Interrogatories and Production of Documents and Incorporated Memorandum 
of Law in Support filed by Jeffrey Epstein. Replies due kl/ 4/6/2009. 
(Attachments: # 1 Exhibit A, # 2 Exhibit B, # a Exhibit )(Critton, Robert) 
(Entered: 03/25/2009) 
03/25/2009 
11_ 
ORDER Granting 68 Motion to Exceed Page Limitation. Signed by 
Magistrate Judge Linnea R. Johnson on 3/24/2009. (sa) (Entered: 03/25/2009) 
03/25/2009 
U Defendant's MOTION to Stay re 62 Amended Complaint by Jeffrey Epstein. 
Responses due by 4/13/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # a 
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Exhibit I)(Pike, Michael) (Entered: 03/25/2009) 
03/27/2009 
71 MOTION for Protective Order Against Piecemeal Depositions ofJane Doe 
No. 4, Motion to Consolidate Cases for Purposes of Discovery, and 
Incorporated Memorandum of Law by Jane Doe No. 4. (Attachments: # 1 
Exhibit A, # 2 Exhibit B)(Mermelstein, Stuart) (Entered: 03/27/2009) 
04/0' 009 
:74 Defendant's MOTION to Compel Response to 1st RTP by Jeffrey Epstein. 
Responses due by 4/20/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 
Exhibit , # 4 Exhibit D)(Critton, Robert) (Entered: 04/02/2009) 
04/02/2009 
715 
Defendant's MOTION to Compel Answers to 1st Interrogs by Jeffrey Epstein. 
Responses due by 4/20/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # a 
Exhibit I(Critton, Robert) (Entered: 04/02/2009) 
04/02/2009 
76 Defendant's ANSWER and Affirmative Defenses to Amended Complaint 
(Second) by Jeffrey Epstein.(Critton, Robert) (Entered: 04/02/2009) 
04/03/2009 
72 Unopposed MOTION for Extension of Time to File Reply as to 20 Response 
to Motion, to Compel Answers to Interrogatories and Production of 
Documents by Jane Doe No. 4. (Attachments: # 1 Text of Proposed Order) 
(Mermelstein, Stuart) (Entered: 04/03/2009) 
04/06/2009 
71 Defendant's MOTION for Extension of Time to File Response as to 21 
MOTION for Protective Order Against Piecemeal Depositions of Jane Doe 
No. 4, Motion to Consolidate Cases for Purposes of Discovery, and 
Incorporated Memorandum of Law by Jeffrey Epstein. (Pike, Michael) 
(Entered: 04/06/2009) 
04/07/2009 
79 ENDORSED ORDER granting 71 Motion for Extension of Time to Respond 
re 7,1 MOTION for Protective Order Against Piecemeal Depositions ofJane 
Doe No. 4, Motion to Consolidate Cases for Purposes of Discovery, and 
Incorporated Memorandum of Law. Responses due by 4/13/2009. Signed by 
Judge Kenneth A. Marra on 4/7/2009. (ir) (Entered: 04/07/2009) 
04/10/2009 
80 Defendant's MOTION for Extension of Time to File Response as to 73 
MOTION for Protective Order Against Piecemeal Depositions ofJane Doe 
No. 4, Motion to Consolidate Cases for Purposes of Discovery, and 
Incorporated Memorandum of Law, 79 Order on Motion for Extension of 
Time to File Response/Reply/Answer, (Amended) by Jeffrey Epstein. (Pike, 
Michael) (Entered: 04/10/2009) 
04 1 
'00() 
81 ENDORSED ORDER granting (73) Motion for Extension of Time to Respond 
re (66 in 9:08-cv-80119-ICAM) MOTION for Protective Order and to Quash 
Subpoena for Deposition ofJane Doe No. 3, Motion to Consolidate Cases for 
Purposes of Discovery, and Incorporated Memorandum of Law In Support in 
case 9:08-cv-80119-ICAM; granting (65) Motion for Extension of Time to 
Respond re (66 in 9:08-cv-80119-KAM) MOTION for Protective Order and 
to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate 
Cases for Purposes of Discovery, and Incorporated Memorandum of Law in 
Support in case 9:08-cv-80232-KAM; granting (80) Motion for Extension of 
'rime to Respond re (66 in 9:08-cv-80119-KAM) MOTION for Protective 
Order and to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to 
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Consolidate Cases for Purposes of Discovery, and Incorporated 
• 
Memorandum of Law in Support in case 9:08-cv-80380-KAM; granting (31) 
Motion for Extension of Time to Respond re (66 in 9:08-cv-80119-KAM) 
MOTION for Protective Order and to Quash Subpoena for Deposition of Jane 
Doe No. 3, Motion to Consolidate Cases for Purposes of Discovery, and 
Incorporated Memorandum of Law in Support in case 9:08-cv-80993-KAM in 
case 9:08-cv-80119-KAM. Responses due by 4/16/2009. Signed by Judge 
Kenneth A. Marra on 4/13/2009. (ir) (Entered: 04/13/2009) 
04/13/2009 
$2 Unopposed MOTION for Extension of Time to File Response/Memorandum 
in Opposition to Motion to Stay and/or Continue Action by Jane Doe No. 4. 
(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 
04/13/2009) 
04/14/2009 
83 ENDORSED ORDER granting (75) Motion for Extension of Time to Respond 
re (65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56) 
Amended Complaint in case 9:08-cv-80119-KAM; granting (67) Motion for 
Extension of Time to Respond re (65 in 9:08-cv-80119-ICAM) Defendant's 
MOTION to Stay re (56) Amended Complaint in case 9:08-cv-80232-ICAM; 
granting (82) Motion for Extension of Time to Respond re (65 in 9:08-cv-
80119-KAM) Defendant's MOTION to Stay re (56) Amended Complaint in 
case 9:08-cv-80380-KAM; granting (73) Motion for Extension of Time to 
Respond re (65 in 9:08-cv-80119-ICAM) Defendant's MOTION to Stay re (56) 
Amended Complaint in case 9:08-cv-80381-ICAM; granting (33) Motion for 
Extension of Time to Respond re (65 in 9:08-cv-80119-KAM) Defendant's 
MOTION to Stay re (56) Amended Complaint in case 9:08-cv-80993-KAM; 
granting (27) Motion for Extension of Time to Respond re (65 in 9:08-cv-
80119-KAM) Defendant's MOTION to Stay re (56) Amended Complaint in 
case 9:08-cv-80994-KAM in case 9:08-cv-80119-KAM. ( Responses due by 
4/23/2009). Signed by Judge Kenneth A. Marra on 4/14/2009. (ir) (Entered: 
04/14/2009) 
04/16/2009 
84 Defendant's MOTION for Extension of Time to File Response as to 23. 
MOTION for Protective Order Against Piecemeal Depositions of Jane Doe 
No. 4, Motion to Consolidate Cases for Purposes ofDiscovery, and 
Incorporated Memorandum of Law, by Jeffrey Epstein. (Pike, Michael) 
Modified on 4/20/2009 (Is). (Entered: 04/16/2009) 
04/17/2009 
85 ENDORSED ORDER granting (77) Motion for Extension of Time to Respond 
re (66 in 9:08-cv-80119-ICAM) MOTION for Protective Order and to Quash 
Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate Cases for 
Purposes of Discovery, and Incorporated Memorandum of Law in Support in 
case 9.08-cv-80119-ICAM; granting (84) Motion for Extension of Time to 
Respond re (66 in 9:08-cv-80119-ICAM) MOTION for Protective Order and 
to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate 
Cases for Purposes of Discovery, and Incorporated Memorandum of Law in 
Support in case 9:08-cv-80380-KAM; granting (35) Motion for Extension of 
Time to Respond re (66 in 9:08-cv-80119-ICAM) MOTION for Protective 
Order and to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to 
Consolidate Cases for Purposes of Discovery, and Incorporated 
Memorandum of Law in Support in case 9:08-cv-80993-KAM in case 9:08-cv-
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80119-KAM. ( Responses due by 4/24/2009). Signed by Judge Kenneth A. 
Marra on 4/17/2009. (ir) (Entered: 04/17/2009) 
04/17/2009 
$6 RESPONSE to Motion re 23 MOTION for Protective Order Against 
Piecemeal Depositions ofJane Doe No. 4, Motion to Consolidate Cases for 
Purposes of Discovery, and Incorporated Memorandum of Law filed by 
Jeffrey Epstein. Replies due by 4/27/2009. (Pike, Michael) (Entered: 
04/17/2009) 
04/17/2009 
al Unopposed MOTION for Extension of Time to File Response as to 24 
Defendant's MOTION to Compel Response to 1st RTP, 25 Defendant's 
MOTION to Compel Answers to 1st Interrogs by Jane Doe No. 4. 
(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 
04/17/2009) 
04/20/2009 
al MEMORANDUM in Support re 63 Plaintiffs MOTION to Compel Answers 
to Interrogatories and Production of Documents and Incorporated 
Memorandum of Law in Support by Jane Doe No. 4. (Mermelstein, Stuart) 
(Entered: 04/20/2009) 
04/23/2009 
89 RESPONSE in Opposition re 22 Defendant's MOTION to Stay re 62 
Amended Complaint filed by Jane Doe No. 4. (Mermelstein, Stuart) (Entered: 
04/23/2009) 
04/27,2009 
90 ORDER Granting 22 Unopposed Motion for Extension of Time to File Reply 
Memoranda re 20 Response to Motion to Compel Answers to Interrogatories 
and Production of Documents. Reply due by 4/20/2009.Signed by Magistrate 
Judge Linnea R. Johnson on 4/27/2009. (sa) (Entered: 04/27/2009) 
04/27/2009 
91 ORDER Granting fil Unopposed Motion for Extension of Time to Reply to 24 
Defendant's MOTION to Compel Response to First Request to Produce, 25 
Defendant's MOTION to Compel Answers to First set of Interrogatories. 
Reply due by 4/29/2009. Signed by Magistrate Judge Linnea R. Johnson on 
4/27/2009. (sa) (Entered: 04/27/2009) 
04/27/2009 
92
MEMORANDUM in Support re 23 MOTION for Protective Order Against 
Piecemeal Depositions of Jane Doe No. 4, Motion to Consolidate Cases for 
Purposes of Discovery, and Incorporated Memorandum of Law by Jane Doe 
No. 4. (Mermelstein, Stuart) (Entered: 04/27/2009) 
04/29/2009 
93 ORDER granting 23 Motion for Protective Order and Consolidating Cases for 
Purposes of Discovery. Signed by Judge Kenneth A. Marra on 4/28/2009. 
(cqs) (Entered: 04/29/2009) 
04/29/2009 
94 Unopposed MOTION for Extension of Time to File Response as to 24 
Defendant's MOTION to Compel Response to 1st RTP, 25 Defendant's 
MOTION to Compel Answers to 1st Interrogs by Jane Doe No. 4. 
(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 
04/29/2009) 
05/01/2009 
25 ORDER Granting 94 Unopposed Motion for Extension of Time to Response 
to 24 Defendant's MOTION to Compel Answers to First Request to Produce 
25 Defendant's MOTION to Compel Answers to First set of Interrogatories. 
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Response due by 5/6/2009. Signed by Magistrate Judge Linnea R. Johnson on 
5/1/2009. (sa) (Entered: 05/01/2009) 
05/04/2009 
2.6 MEMORANDUM in Opposition re 93 Order on Motion for Protective Order 
by Jeffrey Epstein. (Pike, Michael) (Entered: 05/04/2009) 
05/05/2009 
22 Defendant's MOTION for Extension of Time to File Reply as to $2 Response 
in Opposition to Motion to Stay by Jeffrey Epstein. (Pike, Michael) (Entered: 
05/05/2009) 
05/06/2009 
98 ENDORSED ORDER granting (89) Motion for Extension of Time to Reply re 
(65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56) Amended 
Complaint; granting (81) Motion for Extension of Time to Reply re (65 in 
9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56) Amended 
Complaint in case 9:08-cv-80232-KAM; granting (97) Motion for Extension 
of Time to Reply re (65 in 9:08-cv-80119-ICAM) Defendant's MOTION to 
Stay re (56) Amended Complaint in case 9:08-cv-80380-KAM; granting (82) 
Motion for Extension of Time to Reply re (65 in 9:08-cv-80119-ICAM) 
Defendant's MOTION to Stay re (56) Amended Complaint in case 9:08-cv-
80381-KAM; granting (46) Motion for Extension of Time to Reply re (65 in 
9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56) Amended 
Complaint in case 9:08-cv-80993-KAM; granting (37) Motion for Extension 
of Time to Reply re (65 in 9:08-cv-80119-ICAM) Defendant's MOTION to 
Stay re (56) Amended Complaint in case 9:08-cv-80994-KAM in case 9:08-
cv-80119-ICAM. ( Replies due by 5/20/2009.). Signed by Judge Kenneth A. 
Marra on 5/5/2009. (ir) (Entered: 05/06/2009) 
05/06/2009 
22 RESPONSE in Opposition re 25 Defendant's MOTION to Compel Answers to 
1st Interrogs and for an Award of Reasonable Expenses filed by Jane Doe No. 
4. ((Iorowitz, Adam) (Entered: 05/06/2009) 
05/06/2009 
100 RESPONSE in Opposition re 24 Defendant's MOTION to Compel Response 
to 1st RTP , Overrule Objections and for an Award of Reasonable Expenses 
filed by Jane Doe No. 4. (Attachments: # 1 Exhibit A)(Horowitz, Adam) 
(Entered: 05/06/2009) 
05/06/2009 
101 Defendant's MOTION to Compel Identity Doe #4 in Style of Case and Third-
Party Subpoenas by Jeffrey Epstein. Responses due by 5/26/2009 
(Attachments: # 1 Exhibit Exhibit A)(Pike, Michael) (Entered: 05/06/2009) 
05/11/2009 
102 Defendant's MOTION for Order requiring that plaintiff use Proper Case Style 
in all Filings by Jeffrey Epstein. (Critton, Robert) Modified on 5/13/2009 (Is). 
[Text modified by Clerk] (Entered: 05/11/2009) 
05/13/2009 
103 Clerks Notice of Docket Correction and Instruction to Filer re 102 Defendant's 
MOTION Require Plaintiff to Use Proper Case Style filed by Jeffrey Epstein. 
Error - Docket text does not match document; Correction - Docket text 
modified by Clerk. It is not necessary to refile this document. (Is) (Entered: 
05/13/2009) 
05/13/2009 
la 
RESPONSE/REPLY to 89 Response in Opposition to Motion to Stay and/or 
Continue Action by Jeffrey Epstein. (Pike, Michael) (Entered: 05/13/2009) 
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05/14/2009 
Cases associated. (dg) (Entered: 05/14/2009) 
05/14/2009 
1(1,1 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 
if& 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 
107 ORDER terminating 72 Motion to Stay; terminating 101 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 5/15/2009. (Ic3) 
(Entered: 05/14/2009) 
05/14/2009 
108 ORDER denying 102 Motion. See Order consolidating cases.. Signed by 
Judge Kenneth A. Marra on 5/15/2009. (1c3) (Entered: 05/14/2009) 
05/18/2009 
1_09 
Defendant's MOTION for Extension of Time to File Reply as to (39 in 9:08-
cv-80994-KAM) Response in Opposition to Motion, (40 in 9:08-cv-80994-
KAM) Response in Opposition to Motion by Jeffrey Epstein. Associated 
Cases: 9:08-cv-80119-ICAM et al.(Pike, Michael) (Entered: 05/18/2009) 
05/19/2009 
no 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-ICAM et al.(Pike, Michael) (Entered: 05/19/2009) 
05/19/2009 
al. MOTION for Leave to Withdraw as Co-Counsel by Jeffrey Epstein. 
(Attachments: # I Text of Proposed Order)(Tein, Michael) Event Modified on 
5/20/2009 (ail). (Entered: 05/19/2009) 
05/20/2009 
112 ORDER terminating (93) Motion to Strike ; terminating (94) Motion in case 
9:08-cv-80232-KAM; terminating (110) Motion to Strike ; terminating (111) 
Motion in case 9:08-cv-80380-ICAM; 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-cv-80811-ICAM; 
terminating (62) Motion to Strike in case 9.08-cv-80893-ICAM; terminating 
(62) Motion to Strike in case 9:08-cv-80993-KAM; terminating (50) Motion 
to Strike in case 9:08-cv-80994-ICAM. Signed by Judge Kenneth A. Marra on 
5/20/2009. (1c3) (Entered: 05/20/2009) 
05/20/2009 
al 
NOTICE by 
. of Filing Withdrawal of Previously Raised 
• 
ions to 
Defendant, e ey pstein's Motion to Compel And/Or Identify 
. in the 
Style of This Case and Motion to Identifr C.M.A. 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 
114 Clerks Notice of Docket Correction and Instruction to Filer re 111 MOTION 
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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 
115 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 
116 Clerks Notice of Docket Correction and Instruction to Filer re 110 MOTION 
to Strike filed by Jeffrey Epstein. Error - Motion with Multiple Reliefs Filed 
as One Relief;. Instruction to filer - In the future, please select all applicable 
reliefs. It is not necessary to refile this document. (Is) (Entered: 05/21/2009) 
05/21/2009 
Ili 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) by Jane Doe No. 
6, Jane Doe No. 7, Jane Doe, Jane Doe No. 5, Jane Doe No. 4, Jane Doe No. 
3. Associated Cases: 9:08-cv-80119-ICAM et al.(Mermelstein, Stuart) 
(Entered: 05/21/2009) 
05/22/20)o) 
118 ORDER terminating (100) Motion for Extension of Time to Respond in case 
9:08-cv-80232-KAM; terminating (117) Motion for Extension of Time to 
Respond in case 9:08-cv-80380-KAM; terminating (101) Motion for 
Extension of Time to Respond in case 9:08-cv-80381-KAM; terminating (67) 
Motion for Extension of Time to Respond in case 9:08-cv-80993-KAM; 
terminating (54) Motion for Extension of Time to Respond in case 9:08-cv-
80994-KAM. The attorneys are instructed again to ONLY file this type of 
motion in case no. 08-80119. See Order consolidating cases for details.. 
Signed by Judge Kenneth A. Marra on 5/22/2009. (1c3) (Entered: 05/22/2009) 
05/27/2009 
119 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 
120 ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in case 
08-80119. This Notice should only be filed in 08-80119, not in all of the 
Epstein cases... Signed by Judge Kenneth A. Marra on 5/28/2009. Associated 
Cases: 9:08-cv-80119-KAM et al. (1c3) (Entered: 05/28/2009) 
05/29/2009 
121 NOTICE of Attorney Appearance by 
. 
on behalf of 
United States of America Associated Cases: 9:08-cv-80119-KAM et al.
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(
, 
) (Entered: 05/29/2009) 
05/29/2009 
122 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-ICAM) 
Defendant's MOTION to Stay re (18) Amended Complaint, (22 in 9:08-cv-
80993-1CAM) 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 
AmiSlies dta 6/8/2009. Associated Cases: 9:08-cv-80119-ICAM et 
al ( 
M 
(Entered: 05/29/2009) 
05 '9 2001) 
123 RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's 
MOTION to Compel Identifr Doe in Style of Case and in Third-Party 
Subpoenas, (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 
enhy 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 
124 ORDER STRIKING (124 in 9:08-cv-80119-ICAM, 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-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-
KAM et al. (Ic3) (Entered: 05/29/2009) 
05/29/2009 
121 MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION TO 
DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, TO 
UNSEAL THE NONPROSECUTIONAGREEMEIVT 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 
12¢ 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 
127 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-ICAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv-80811-
KAM) Motion to Continue Hearing filed by Jane Doe No. 102, Jane Doe No. 
101, (76 in 9:08-cv-80993-ICAM, 109 in 9:08-cv-80381-ICAM, 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 
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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. 
(Ic3) (Entered: 06/01/2009) 
06/01/2009 
Reset Scheduling Order Deadlines: Calendar Call set for 5/28/2010 10:00 AM 
in West Palm Beach Division before Judge Kenneth A. Marra., Jury Trial set 
for 6/1/2010 09:00 AM in West Palm Beach Division before Judge Kenneth 
A. Marra., Discovery due by 12/11/2009., Dispositive Motions due by 
1/8/2010. (ir) (Entered: 06/01/2009) 
06/04/2009 
128 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 
129 ORDER STRIKING (112 in 9:08-cv-80381-KAM, Ill in 9:08-cv-80232-
KAM, 136 in 9:08-cv-80119-KAM, Ill in 9:08-cv-80811-ICAM, 128 in 9:08-
cv-80380-KAM, 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-
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-80119-1CAM et al. (1c3) 
(Entered: 06/04/2009) 
06/08/2009 
130 RESPONSE to Motion re (91 in 9:08-ev-80119-1CAM) 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-
1C.AM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/08/200') 
131 NOTICE by Jane Doe re (113 in 9:08-cv-80119-ICAM) Plaintiff's MOTION 
Plaintiffs Jane Doe No. 101 and Jane Doe I02's Motion for No-Contact Order 
-Plaintiffs Jane Does 2-7 Notice of Joinder Associated Cases: 9:08-cv-80119-
1CAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/09/2009 
132 Unopposed MOTION to Amend/Correct 2¢ Answer to Amended Complaint 
by Jeffrey Epstein. Responses due by 6/26/2009 (Attachments: # I Exhibit 
"A", # 2 Exhibit "B", # a Text of Proposed Order Order)(Pike, Michael) 
(Entered: 06/09/2009) 
PACER Service Center 
Transaction Receipt 
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PACER Login:liciu4480 
IIClient Code: 
Description: 
Billable Pages: 
Docket Report 
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Search Criteria: 
Cost: 
9:08-cv-80380-
KAM 
0.88 
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Document 54 
Entered 
FLSD Docket 10/ 
2008 
Page 1 of 10 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80380-MARRA-JOHNSON 
JANE DOE NO. 4 
1. 
Plaintiff, 
JEFFREY EPSTEIN 
Defendant. 
DEFENDANT EPSTEIN'S MOTION TO DISMISS AND MOTION FOR MORE 
DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPLAINT 
Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves 
to dismiss and for more definite statement of Plaintiff JANE DOE NO. 4's Amended 
Complaint. Rules 12(b)(6), and 12(e) and (f), Fed.R.Civ.P. (2008). In support of his 
motion, Defendant states: 
Introduction 
Defendant is filing similar motions to dismiss and for more definite statement 
directed to the Amended Complaints filed against Defendant in this Court in JANE DOE 
NO. 2, JANE DOE NO. 3, JANE DOE NO. 4 and JANE DOE NO. 5. The motions are 
directed to the Counts for "Sexual Assault and Battery," and "Coercion and Enticement 
to Sexual Activity in Violation of 18 
. §2422" in each of the respective complaints. 
However, there are distinctions in the four motions filed based on the complaint 
allegations. For example, Defendant challenges the Plaintiffs' allegations as to assault 
in all four actions, and challenges the battery allegations in JANE DOE NOS. 2 and 3, 
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Page 2 of 10 
Case No. CV-80380-Marra-Johnson 
Page No. 2 
but not in JANE DOE NOS. 4 and 5. Defendant moves to dismiss the §2422 count in all 
four actions. 
Motion 
1. Counts I and III of the Amended Complaint are required to be dismissed for 
failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has 
failed to allege sufficient factual allegations in the Counts and instead alleges labels and 
conclusions, and an attempted formulaic recitation of the elements in each Count. 
2. In the alternative, Defendant seeks more definite statement of Count I and III. In 
Count I, the Plaintiff is required to more definitely allege in the context of the claim for 
assault underlying factual allegations pertaining to the creation in Plaintiff of "imminent 
fear of peril;"; what EPSTEIN said and did, if anything, to create fear and apprehension 
in Plaintiff. In Count III, Plaintiff is required to more definitely state the underlying factual 
allegations to support her claim as set forth in the statute, 18 
. §2422(b) and 
§2455. Rule 12(e). See discussion of law below herein. 
3. Also, Plaintiff's reference in Count III to 28 
. §2255, pertaining to habeas 
corpus proceedings is required to be stricken as immaterial. Rule 12(f). Plaintiff is 
required to more definitely state what statutory provision she is relying on. Rule 12 (e). 
WHEREFORE, Defendant respectfully requests that this Court dismiss Counts I and 
III, strike the immaterial statutory reference, and require Plaintiff to more definitely plead 
the underlying elements of her claims. 
Supporting Memorandum of Law 
Standard on Rule 12(b)(6) Motion To Dismiss 
As established by the Supreme Court in Bell Atlantic Corp.'. Twombly 127 
S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead 
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"enough facts to state a claim to relief that is plausible on its face." Id, at 1974. 
Although the complaint need not provide detailed factual allegations, the basis for relief 
in the complaint must state "more than labels and conclusions, and a formulaic 
recitation of the elements of a cause of action will not do." Id, at 1965. Further, "[f]actual 
allegations must be enough to raise a right to relief above the speculative level ... on the 
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. 
DeKalb County 
Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006). 
Significantly, the Supreme Court in Bell Atlantic Corp.'. Twomblv 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 not set of facts in 
support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley 
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) moti 
to dismiss does not 
need detailed factual allegations, ibid.; Saniva 
. American Bd. of 
Psychiatry and Neuroloay. Inc. 40 F.3d 247, 251 
.7 1994), a plaintiffs 
obligation to provide the "grounds" of his "entitle[ment] to relief' requires 
more than labels and conclusions, and a formulpic recitation of the elements 
of a cause of action will not do, see Papasan I. 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 Quist be enough to raise a right to relief 
above the speculative level, see 5
 Wright & A. Miller Federal Practice and 
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