Case 9:09-cv-80802-KAM

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Entered on FLSD Docket 08/11/2009

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 09-CV-80802-MARRA/JOHNSON

JANE DOE NO. 8,
 Plaintiff,
 vs.
JEFFREY EPSTEIN,
 Defendant.
/

PLAINTIFF JANE DOE NO. 8'S UNOPPOSED MOTION TO CONSOLIDATE FOR DISCOVERY PURPOSES

Plaintiff, Jane Doe No. 8, by and through undersigned counsel, files this Unopposed Motion to Consolidate for Discovery Purposes, and states as follows:

1. This case involves the alleged sexual abuse of Jane Doe No. 8 in 2001 by Jeffrey Epstein in Palm Beach, Florida.

2. The facts of this case arise from the same series of events as the multiple cases pending in this Court against Jeffrey Epstein which are consolidated for purposes of discovery as Jane Doe No. 2 v. Jeffrey Epstein , Case no. 08-CV-80119-Marra/Johnson.

3. It is anticipated by the parties that there will be a significant overlap in witnesses, evidence, and depositions in this case and the consolidated proceedings.

4. Accordingly, Jane Doe No. 8 requests that this Court consolidate this case with Jane Doe No. 2 v. Jeffrey Epstein , Case no. 08-CV-80119-Marra/Johnson and consolidated cases, for purposes of discovery only and amend the caption of the consolidated cases accordingly.

5. Prior to the filing of this Motion, Plaintiff’s counsel conferred with Defendant’s

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Case 9:09-cv-80802-KAM

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counsel, who advised that Defendant does not oppose the relief requested.

Dated: August 11, 2009. Respectfully submitted,

By: s/ Adam D. Horowitz
Stuart S. Mermelstein (FL Bar No. 947245)
ssm@sexabuseattorney.com
Adam D. Horowitz (FL Bar No. 376980)
ahorowitz@sexabuseattorney.com
MERMELSTEIN & HOROWITZ, P.A.
Attorneys for Plaintiff Jane Doe 8
18205 Biscayne Blvd., Suite 2218
Miami, Florida 33160
Tel: 305-931-2200
Fax: 305-931-0877

CERTIFICATE OF SERVICE

I hereby certify that on August 11, 2009, 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 to all parties on the attached Servi ce List in the manner specified, either vi a 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 Notices of Electronic Filing.

/s/ Adam D. Horowitz

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SERVICE LIST
DOE vs. JEFFREY EPSTEIN
CASE NO.: 09-CV-80802-MARRA/JOHNSON
United States District Court, Southern District of Florida

Jack Alan Goldberger, Esq.
jgoldberger@agwpa.com

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

/s/ Adam D. Horowitz

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court-records/Doe No. 8 v. Epstein, No. 909-cv-80802 (S.D. Fla. 2009)/011.pdf
{"year":"2009","court":"S.D. Fla","people":["jeffrey epstein","adam d. horowitz","stuart s. mermelstein","jack goldberger","robert d. critton"]}