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

EFTA Document EFTA01660024

Rol Slack lir „kite'

Rol Slack lir „kite' 2/949 Arcrwite a." 2434 7 Antai, Liu) 3 cut, , 4,/e EFTA00183732 KIRKLAND & ELLIS LLP AND AfilL/ArtO PART/H.3We; ' Cntercup Cantor 163 East 53'd Street New York, New York 10022-4611 WNW rwerA.COM September 2, 2008 VIA FACSIMILE (56D 820-8777 United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re:Jeffrey Bpstein Dear • Facsimile: In response to your letter dated August 26, 2008, I am confirming that Mr. Goldberger should continue to be listed as the contact pawn in the' mended victim notification letters and should receive the carbon copies of thoso letters as they are sent. • Also, we plan on speaking to Mr. Josofsberg this week to discuss a procedure for paying his fees. We intend to comply fully with the agreement and Mr. Epstein will pay Mr. Josfsberg's usual and customary hourly rates for his work pursuant to the agreement facilitating settlements unde

EFTA00013564

Case 9:08-cv-80232-KAM

Case 9:08-cv-80232-KAM Document 16 Entered on FLSD Docket 07'16'2008 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80232-CIV-MARRA/JOHNSON JANE DOE NO. 3, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO SEAL THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to File Ex Parte and Under Seal, filed July 10, 2008. Defendant seeks to file a Notice of Continued Pendency of Federal Criminal Action under seal.' The Court has carefully considered the motion and the record and is otherwise fully advised in the premises. As stated in the Local Rules for the Southern District of Florida, "proceedings in the United States District Court are public and Court filings are matters of public record." S.D. Fla. L.R. 5.4(A). It is well settled that the media and the public in general possess a common-law right to inspect and copy judicial records. See Nixon I Warner Communications, Inc., 435 U.S. 589, 597 (1978).

Case 9:08-cv-80893-KAM

Case 9:08-cv-80893-KAM Document 38 Entered on FLSD Docket 04/17/2009 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 08-CIV-80893 - MARRA/JOHNSON JANE DOE, 1. Plaintiff, JEFFREY EPSTEIN, Defendant. / PLAINTIFF'S FIRST AMENDED COMPLAINT Parties, Jurisdiction and Venue Plaintiff, Jane Doe, hereby brings this First Amended Complaint against Defendant, Jeffrey Epstein, and states as follows: 1. This is an action for damages in an amount in excess of $50,000,000.00, exclusive of interest and costs. 2. This First Amended Complaint is brought under a fictitious name in order to protect the identity of Plaintiff, Jane Doe, because this Complaint makes allegations of sexual assault and child abuse of a then minor. 3. At all times material to this cause of action, Plaintiff, Jane Doe, was a resident of Palm Beach County, Florida. 4. At all times material to this cause of action, Defendant, Jeffrey Epstein, was a resident of the State