Cas910880119 AM Document 15513212910f44

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

JANE DOE,
CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON

Plaintiff,

Vs.

JEFFREY EPSTEIN, et al.

Defendant.

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 PROTECTIVE RESPONSE TO DEFENDANT’S MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL

Plaintiff, Jane Doe, hereby files this protective response to Defendant’s Consolidated Rule 4 Review and Appeal of Portions of the Magistrate’s Orders Dated February 4, 2010 (DE 462), (DE 480) and April 1, 2010 (DE 513), with Incorporated Objections and Memorandum of Law (doc. #454).

Jane Doe had understood that she had fully briefed the issues raised by the defendant’s pleading when on March10, 2010, she filed her response in Opposition to Defendant’s Motion for Reconsideration (doc. #485). It appears, however, the defendant Epstein may view his “consolidated” appeal as requiring some sort of new response from Jane Doe. If so, Jane Doe wishes to make clear that she continues to

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## CASE NO: 08-CV-80119-MARRA/JOHNSON

assert the responses she raised in her earlier response and hereby files this protective response incorporating by reference all of her earlier arguments.

Jane Doe would also note she filed her request for these documents on July 20, 2009. Through a seemingly endless series of motions, all of which have been rejected on the merits, Epstein has blocked turning over tax returns and other documents that the Government has already seen on Fifth Amendment grounds for more than ten months. Jane Doe’s trial date is less than two months away on July 19, 2010, and she needs the requested items soon to prepare for trial.

Jane Doe attempted to negotiate a resolution to these issues with counsel for Epstein, but the negotiations failed.

Jane Doe therefore respectfully requests that the Court promptly order production of these documents to her.

DATED: May 27, 2010

Respectfully Submitted,

s/ Bradley J. Edwards
Bradley J. Edwards
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Telephone (954) 524-2820
Facsimile (954) 524-2822
Florida Bar No.: 542075
E-mail: brad@pathtojustice.com

and

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33044

CASE NO: 08-CV-80119-MARRA/JOHNSON

Paul G. Cassell

Pro Hac Vice

332 S. 1400 E.

Salt Lake City, UT 84112

Telephone: 801-585-5202

Facsimile: 801-585-6833

E-Mail: cassellp@law.utah.edu

## CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 27, 2010 I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing.

s/ Bradley J. Edwards
Bradley J. Edwards

## SERVICE LIST

## Jane Doe v. Jeffrey Epstein

United States District Court, Southern District of Florida

Jack Alan Goldberger, Esq.
Jgoldberger@agwpa.com

Robert D. Critton, Esq.
rcritton@bclclaw.com

Isidro Manual Garcia
isidrogarcia@bellsouth.net

Jack Patrick Hill
iph@searcylaw.com

Katherine Warthen Ezell
KEzell@podhurst.com

Michael James Pike

3

Case 9910880119KAM

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CASE NO: 08-CV-80119-MARRA/JOHNSON

## MPike@bclclaw.com

Paul G. Cassell
cassellp@law.utah.edu

Richard Horace Willits
lawyerswillits@aol.com

Robert C. Josefsberg
rjosefsberg@podhurst.com

Adam D. Horowitz
ahorowitz@sexabuseattorney.com

Stuart S. Mermelstein
ssm@sexabuseattorney.com

4
documents/doj-4f31a4acf4beb8e5.pdf
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