Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 105 Entered on FLSD Docket 05:19/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION FOR LEAVE TO WITHDRAW AS CO-COUNSEL LEWIS TEIN, P.L. hereby moves for leave to withdraw as co-counsel for defendant Jeffrey Epstein, stating as follows: 1. On December 30, 2008, Lewis Tein filed its notice of withdrawal as counsel for Mr. Epstein [DE 53], noting that two other law firms who previously entered their appearance on Mr. Epstein's behalf would remain as co-counsel. 2. We have since learned through discussions with the Clerk of Court that absent a formal order of withdrawal by this Court, Lewis Tein will continue to be listed as counsel for Mr. Epstein on the CM/ECF. 3. Accordingly, Lewis Tein respectfully requests that this Court enter an order allowing it to withdraw as counsel for Mr. Epstein. Lewis 'reins.

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 31 Entered on FLSD Docket 07 29 '2008 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. I JANE DOE NO. 3, vs. JEFFREY EPSTEIN. JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-ICAM-LRJ CASE NO.: 08-80232-CIV-KAM-LRJ CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ DEFENDANT'S NOTICE OF FILING EXHIBITS Defendant Jeffrey Epstein hereby files the following two exhibits to his Reply in Support of Motion to Stay, filed under seal on July 28, 2008: A. Exhibit "A" is the July 9, 2008 Declaration of Assistant United States Attorney , M previously filed by the United States in In re: Jane Doe, Case No. 08- 80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14). LeaTsinri 3059 GRAND Avavue. Surn 340.COCONtri GROvE. FLORIDA 33133 EFTA00221651 Case 9:08-cv-80119-KAM Document 31 Entered on FLSD Docket 07'29'2008 Page 2 of 3

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Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 12 Entered on FLSD Docket 06/20/2008 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DEFENDANT'S MOTION FOR STAY Defendant Jeffrey Epstein respectfully moves for a mandatory stay of this action under Title 18, United States Code, Section 3509(k). As discussed below, this action is subject to a mandatory stay based on the existence of two pending parallel criminal actions. Introduction This civil action is a private counterpart to two ongoing criminal actions, one in Palm Beach state court, the other in Miami federal court. Both cases purport to arise from the same occurrence: the alleged sexual assault of a minor, Jane Doe No. 2. A federal statute directly on point provides that when an alleged sexual assault involving a child victim results in a "criminal proceeding," a commonly EFTA00221641 Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 25 Entered on FLSD Docket 0718/2008 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MEMORANDUM OF LAW IN RESPONSE TO DEFENDANT'S MOTION FOR STAY Plaintiff, Jane Doe No. 2, by and through her undersigned counsel, submits this Memorandum of Law in Response to Motion for Stay, as follows: INTRODUCTION Defendant Jeffrey Epstein's Motion to Stay this action is based on the incorrect premise that there are criminal actions pending against him in Palm Beach Circuit Court, State of Florida. Jeffrey Epstein, Case No. 2006 CF 09454 AXXMB (Fifteenth Judicial Circuit, Palm Beach County), and in the Southern District of Florida, In re Grand Jury, No. FGJ 07-103 (WPB) (S.D. Fla.). The Motion to Stay as to the state court criminal action was rendered moot on June 30, 2008 when Jeffrey Epstein entered a plea of guilty to