Case 9:08-cv-80804-KAM

Case 9:08-cv-80804-KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a JANE DOE #1, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. EPSTEIN'S RESPONSE TO MOTION TO PRESERVE EVIDENCE [DE 121 Defendant Jeffrey Epstein hereby responds to the plaintiff Jane Doe's motion to preserve evidence, as follows: I. The Certificate of Compliance annexed to the plaintiffs motion states that plaintiff's "counsel conferred with counsel for [Mr. Epstein] . . . and [Epstein's] counsel advised that [Epstein] opposelS] this motion." DE 12 at 2 (emphasis added). That certification is inaccurate. 2. On August 21, 2008, counsel for the plaintiff called Kathryn Meyers, Esq. of the Lewis Tein law firm to elicit Epstein's position on this motion. Ms. Meyers responded that she would confer with Mr. Tein and call them back. Less than thirty minutes later, however, plain