letter: DOJ-OGR-00031568

EFTA02728761

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 PLAINTIFF JANE DOE'S EMERGENCY MOTION TO HAVE EPSTEIN HELD IN CONTEMPT FOR FAILING TO PRODUCE STATE DISCOVERY AND CORRESPONDENCE AND FOR PRODUCING ONLY REDACTED CORRESPONDENCE WITH THE U.S. ATTORNEY'S OFFICE AND MOTION FOR SANCTIONS Plaintiff, Jane Doe, through undersigned counsel, hereby files this motion to have defendant Epstein held in contempt for (1) failing to produce any state criminal discovery and any correspondence with state prosecutors, and (2) producing only redacted correspondence with the U.S. Attorney's Office. Both of these failures stand in clear violation of this Court's discovery orders. Jane Doe further asks that Epstein be directed to produce these materia

Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37

Case 9:08-cv-80119-KAM

Letter: DOJ-OGR-00031570

The letter, dated March 28, 2008, is from Stuart S. Mermelstein to Lanna Leigh Belohlavek, requesting coordination on depositions in the Jeffrey Epstein case, and suggesting a single deposition for the victims to be used in both the criminal and civil cases.

UNITED STATES DISTRICT COURT