#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff; vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-801I9-MARRAME CASE NO.: 08-CV-80232-MARRAMIM CASE NO.: 08-CV-80380-MARRA, JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARRAME VS. JEFFREY EPSTEIN, Defendant JANE DOE NO. 6, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80994-MARRAMS JANE DOE NO. 7, CASE NO.: 08-CV-80993-MARRAMII/ PlaintifZ vs. JEFFREY EPSTEIN, Defendant. C.M.A., CASE NO.: 08-CV-Wall-MARRA/NM Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE, CASE NO.: 08-CV80893-MARIWJOIINSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. II, CASE NO.: 08-CV-80469-MARRAIMMI Plaintiff. vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARla Plaintiff; vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 102, CASE NO.: 09-CV-80656-MARRAMMI Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ### PLAINTIFFS JANE DOE NO. 101 and JANE DOE NO. 102'S MOTION FOR NO-CONTACT ORDER Plaintiffs, Jane Doe No. 101 and Jane Doe No. 102 (together, the "Plaintiffs") hereby move this Court for aNo-Contact Order directed to Defendant, Jeffrey Epstein, and, as grounds, state as follows: 1. After investigations by the Palm Beach Police Department, the Palm Beach Stale Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida (the "USAO"), Defendant, Jeffrey Epstein, in June 2008, entered pleas of "guilty" in the Fifteenth Judicial Circuit in Palm Beach Count, Florida, to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution. 1. During the course of Defendant's state plea conference of June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pucillo ordered Defendant "not to have any contact, direct or indirect" with any victims. (Transcript of the Plea Conference at 20, relevant pages attached hereto as Exhibit A). Judge Dale Pucillo went on to clarify that, by "indirect," she meant that Defendant should not send any text messages, e-mails, Facebook contact, My Space contact, telephone calls, voicemaits, or messages through third parties to "any of these victims." Id. Judge Dale Pucillo expressly stated that the no-contact order should apply to "all of the victims." Id. 1. In addition, after Defendant entered into anon-prosecution agreement with the USAO, Assistant United States Attorney Villafafia provided Defendant's attorneys with a list of individuals whom the USAO had identified as victims of child sex exploitation as defined in 18 U.S.C. § 2255 (the "USAO List"). The USAO was prepared to indict Defendant based upon Defendant's sexual exploitation of these minor victims. It was the intent of the USAO to place these identified victims in the same position as they would have been had Defendant been convicted at trial. Thus, upon information and belief, AUSA Villafana and Mr. Michael Tein, former counsel for Defendant, along with Mr. Jack Goldberger, who still represents Defendant, entered into a verbal agreement at the time AUSA Villafafta provided the USAO List to them, whereby neither Defendant, Jeffrey Epstein, nor his agents would have any direct or indirect contact with the victims named on the USAO List. 4. Nevertheless, during a March 25th meeting with Defendant's counsel, Defendant's counsel told Plaintiffs' counsel that it is Defendant's position that the no-contact order agreed to during the state plea conference does not apply to anyone other than those three victims who were officially part of Defendant's state plea. 1. Upon Plaintiffs' counsel seeking reassurance from Defendant's counsel that neither Defendant nor his agents would contact victims on the USAO List, Defendant's counsel responded that Defendant, Jeffrey Epstein, would not contact any of undersigned counsel's clients as long as Mr. Josefsberg was representing them in connection with settlement discussions. 1. As a result, on April 17, 2009, Plaintiffs' counsel sent defense counsel aletter requesting that Defendant provide written confirmation that neither he nor his agents will directly or indirectly contact any of the victims represented by Plaintiffs' counsel (the "No-Contact Letter") (April 17, 2009 Letter attached hereto as Exhibit B). On May 18, 2009, Plaintiffs' counsel again requested this written confirmation (E-mail correspondence attached hereto as Exhibit C). Despite Plaintiffs' reasonable requests, Defendant's counsel first responded by stating that the Non-Prosecution Agreement does not prevent some font of contact with undersigned counsel's clients. (Redacted May 18, 2009 letter from Mr. Robert Critton is attached hereto as Exhibit D). Defendant's counsel then sent aletter on May 21, 2009 citing the Comment to Rule 4-4.2 of the Rules of Professional Conduct that states that "fplarties to a matter may communicate directly with each other." (Redacted May 21, 2009 Letter from Mr. Critton is attached hereto as Exhibit E). Thus, despite Mr. Critton's statement that it is not Defendant's intention to have direct contact with undersigned counsel's clients, Defendant obviously believes he can change his intentions if he so chooses. 7. Defendant, Jeffrey Epstein, is adesignated sexual offender who sexually abused Jane Doe No. 101 and Jane Doe No. 102 when the victims were minors. As aresult of his abuse, Plaintiffs have in the past suffered, now suffer, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of selfesteem, loss of dignity, and invasion of their privacy. Any further direct or indirect contact with Defendant and/or his agents would cause agreat deal of additional damages. Moreover, any desire or need on the part of Defendant to contact these victims---implied by virtue of his refusal to unambiguously confirm that he will not contact them—is disturbing and suspect, at best. At a minimum, Defendant's refusal to avoid contact works as aploy to attempt to keep Plaintiffs in "victim mode." WHEREFORE, Plaintiff respectfully requests this Court to enter an order prohibiting Defendant, Jeffrey Epstein, and any of his agents from any direct or indirect contact with Plaintiffs, except through Plaintiffs' attorney of record through the duration of this Court's order. ### Memorandum In Support As previously stated, during the course of Defendant's state plea conference of June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pacific, ordered Defendant "not to have any contact, direct or indirect" with any of Defendant's victims. However, for what could only be dubious purposes, Defendant seeks to take advantage of the fact that only three of Defendant's numerous victims were officially a part of the State of Florida's criminal prosecution of Defendant and that he entered into anon-prosecution agreement with the USAO. Thus, despil the no-contact order being considered astandard condition of probation or community contr( for sex offenders such as Defendant, and despite his counsel having agreed to a no-contact ordc with AUSA Villafaiia for all of Defendant's victims on the USA° List, Defendant is now takin. the position that neither Judge Dale Pucillo's no-contact order nor his agreement with the USA( via his counsel restricts him from contacting any of the victims except for the three victim directly involved in the state plea. Because of the non-prosecution agreement, there is no federa conviction against Defendant with respect to Plaintiffs and other victims on the USAO List Mu are similarly situated and, thus, no accompanying sentencing court to issue ano-contact order However, each of the victims on the USAO List is supposed to be in the same position as Defendant bad been convicted in federal court. In crimes involving victims, at the time of sentencing, a sentencing judge generally has wide discretion to order that the defendant have ne contact with the victim or victims of the crime or crimes for which the defendant is being sentenced. Where the defendant is given a sentence of probation or community control, the nocontact order can be made acondition of the defendant's supervision. The case for judicial intervention is heightened in cases such as this one, where Defendant has sexually exploited numerous minors. Jane Doe No. 101 and Jane Doe No. 102, like alt of the other young women on the USAO List, were sexually abused by Defendant; any further direct contact with Defendant and/or his agents would cause agreat deal of additional damages. Previous contact by Defendant and his agents with other victims has bad aterrible effect on the young women's ability to heal the scars of Defendant's abuse. Additionally, Defendant's contacting his victims also has the predictable effect of undermining the victims' willingness to proceed with their civil actions against Defendant. Defendant's demonstrated use of his wealth, power, and influence has the immediate effect of intimidating young women who have already been traumatized by his sexual exploitation. Indeed, any desire or need on the part of Defendant to contact his victims, implied by virtue of his refusal to confirm that he will not contact them directly or indirectly, is disturbing and suspect, at best. Plaintiffs thus ask this Court to provide the protection and peace of mind that each of them needs. WHEREFORE, Plaintiffs respectfully move this Court to enter an order granting Plaintiffs' Motion for No-Contact Order prohibiting Defendant, Jeffrey Epstein, from any contact or communication with Plaintiffs Jane Doc No. 101 and Jane Doe No. 102, either directly or indirectly, except through Plaintiffs' attorney of record for the duration of the order. ## CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.I.A.3 On May 18, 2009, undersigned counsel conferred with counsel for Defendant in agood faith effort to resolve the issues raised in this motion, and Defendant's counsel advised that Defendant opposes this motion. Date: May 22, 2009 /s/Rabert C. Josersi:erg Robert C. Josefsberg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. City National Bank Building 25West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) riosefsberaRoodhurst.com kezell(aModhurst.com Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 ### Certificate of Service Ihereby certify that, on May 22, 2009, I electronically filed the foregoing document with the Clerk of the Coen using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified 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 counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. Is/ Robert Josefsberx Ruben C. Josefsberg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. City National flank Building 25 West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) ijosefsbera@podhurst.com kezelltetyclhurst.com Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 #### SERVICE LIST JANE DOE NO. 2 v. JEFFREY EPSTEIN Case No. 08-CV-80119-MAltRA/JOHNSON United States District Court, Southern District of Florida Robert Critton, Esq. Michael I. Pike, Esq. Burman, Critton, Luther & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 Phone: (561) 842-2820 Fax: (561) 515-3148 reritabolclanoin LapikeQbelclaw.cont Counsel for Defendant, Jeffrey Epstein Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 6594300 Fax: (561) 835-8691 jagestAbellsouth.net Co-Counsel for Defendant, Jeffrey Epstein Bruce E. Reinhart, Esq. Bruce E. Reinhart, PA. 250 South Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 202-6360 Fax: (561) 828-0983 ecfabrucereinhattlaw.com Counsel for Co-Defendant, Jack Scarola, Esq. Jack P.M, Esq. Seamy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9456 hattearcvlaw.com ivhe4searcvlaw.com Counsel for Plaintiff CM.A. Adam Horowitz, Esq. Stuart Mermelstein, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Blvd., Suite 2218 Miami, FL 33160 Phone: (305) 931-2200 Fax: (305) 931-0877 ahorowitzlasexabuscattomev.com smermelsteinotexabuseattornev.com Counsel for Plaintiffs in Related Cases Nos. 0840069, 08-80119.0840232, 08-80380, 08- 80381, 08-80993, 08-80994 Spencer Todd Kuvin, Esq. Theodore Jon Leopold, Esq. Leopold Kuvin, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Phone: (561) 515-1400 Fax: (561) 515-1401 skuvinailleopoldkuvin.com deovoldOleopoldkuvin.com Counsel for Plaintiff in Related Case No. 08-08804 Richard Willits, Esq. Richard H. Willits, P.A. 2290 10th Ave North, Suite 404 Lake Worth, FL 33461 Phone: (561) 582-7600 Fax: (561) 588.8819 lawverwillits(alaol.coni reelritwOhotmaiLcom Counsel for Plaintiff in Related Case No. 08-80811 Brad Esq. Law Office of Brad & Associates, LLC 2028 Street, Suite 202 Hollywood, FL 33020 Phone: (954) 414-8033 Fax: (954) 924-1530 bedwarclsarra-law.com beailbradedwanislaw.coui Counsellor Plaintiff in Related Case No. 08-80893 Isidro Manuel Esq. Elkins & Boehringer 224 Datum Avenue, Suite 900 West Palm Beach, FL 33401 Phone: (561) 832-8033 Fax: (561) 832-7137 isidrogarcia(bellsouth.net Counsel for Plaintiff in Related Case No. 08-80469 # EXHIBIT A to Plaintiffs Jane Doe 101 and Jane Doe 102's Motion for No-Contact Order 1 2 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION 3 4 6 7 8 STATE OF FLORIDA ) vs ) CASE NO. 06 CF9454AMB ) 089381CFAMB JEFFREY EPSTEIN Defendant. ) 9 • PLEA CONFERENCE 10 11PRESIDING: HONORABLE DEBORAH DALE PUCILLO 12 APPEARANCES: ON BEHALF OF THE STATE: BARRY E. KRISCHER, ESQUIRE State Attorney North Dixie Highway West Palm Beach, Florida 33401 By: LANNA BELOHLAVEK, ESQUIRE Assistant State Attorney 17 ON BEHALF OF THE DEFENDANT: ATTERBURY, GOLDBERGER & WEISS,P.A. 18250 Australian Avenue South Suite 1400 19West Palm Beach, Florida 33401 By: JACK GOLDBERGER, ESQUIRE 20 21 22 23 June 30, 2008 24Palm Beach County Courthouse West Palm Beach, Florida 33401 25Beginning at 8:40 o'clock, a.m. CERTIFIED COPY regularly congregate? MS. BELOHLAVEK: I personally do not know. THE COURT: Neither do I, which is why L'm asking. Has that been investigated? MR. GOLDBERGER: We have done our due diligence, for what it's worth, there is a residential street. There are not children congregating on that street. We think the address applies, if it doesn't, we fully recognize that he can't live there. THE COURT: Okay. D is, you shall not have any contact with the victim, are there more than one victim? MS. BELOHLAVEK: There's several. THE COURT: Several, all of the victims. So this should be plural. I'm making that plural. You are not to have any contact direct or indirect, and in this day and age I find it necessary to go over exactly what we mean by indirect. By indirect, we mean no text messages, no ezmail, no Face Book, no My Space, no telephone calls, no voice mails, no 1 2 3 4 5 6 messages messages would you afriend, through carrier pigeon, no through third parties, no hey tell so and so for me, no having acquaintance or stranger approach any of these victims with amessage of any sort from you, is that clear? 8 9 10 THE COURT: And then it states, unless approved by the victim, the therapist and the sentencing court. Okay. 11 THE DEFENDANT: I understand. 12 13 14 15 16 THE COURT: And the sentencing court. So, if there is adesire which, I would think would be abit strange to have contact with any of the victims the court must approve it. 17 MS. BELOHLAVEK: Correct. 18 19 20 21 22 23 THE COURT: If the the age of 18, which was shall not until you have attended program. becoming victim was under the Case, you successfully and completed the sex offender So, is this sex offender program acondition of probation? 24 25 don't MS. BELOHLAVEK: That is not. I believe I circled that one. THE DEFENDANT: Yes, # EXHIBIT B to Plaintiffs Jane Doe 101 and Jane Doc 102's Motion for No-Contact Order # Podhurst Orseck TRIAL dr APPELLATE LAWYERS Aaron S. Podhurst RobertSasefsberg Joel D Steven C Maria Victor MM., Jr. Katherine W. Ezell Stephen R Rosenthal Ricardo M -04 Ramon A. Rasco Alexander T. Rtmdlet John Oravante, M Carolina Maharbiz April 17, 2009 ## VIA FACSIMILE David Spicer, Esq. 11000 Prosperity Farms Road Suite 104 Palm Beach Gardens, FL 33410 Robert Critton, Esq. Burman, Critton, Luther & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Gentlemen: Robert Orseric (19341978) wafter H. Beckham, Jr. Karen Podhurst Dem Of Counsel During our recent meeting with Mr. Black, we were told that it is your client's position that the no-contact order agreed to during the state plea colloquy does not apply to any of our clients except for those victims who were part of Mr. Epstein's state plea. Our understanding is that AUS A Villafana and Messrs. Tein and Goldberger entered a verbal agreement at the time that the list of victims was provided to those defense counsel that Mr. Epstein, including his agents, would have no direct or indirect contact with the victims named on this list. In addiditon, under applicable Florida Bar Rules governing contact by attorneys and their agents with persons represented by counsel, any contact with any of our clients or their family members by Mr. Epstein, his counsel and/or his agents must strictly be through us. Mr. Leficowitz had previously reassured us that Mr. Epstein would not contact any of our clients as long as I am "representing them in connection with settlement discussions." Due to our differences regarding the retroactivity issue and the "per plaintiff' v. per incident/count issue, we have apparently reached a dead end regarding settlement We are concerned that Mr. Epstein could misconstrue ow impasse in conjunction with Mr. Lefkowitz' e-mail to mean that now that we are no longer "representing them in connection with settlement discussions," he may contact them. Pleasebe assured that it is our position that regardless of whether we are representing our clients during settlement discussions and/or trial preparation, we, and the rules of professional conduct, prohibit contact. In other to be crystal clear as to whom we represent, we have attached a list of our present clients. We expect each member of Mr. Epstein's defense team to abide by the applicable rules of professional conduct. We request written confirmation from Mr. Epstein that neither he nor his agents will contact any of the victims represented by us. If this correspondence is in any way unclear, please contact us. Sincerely, Robert C. 74Jo -t berg cc: Roy Black, Esq. w/ enclosures Jay Lefkowitz, Esq. w/ enclosures ## List of Clients Represented by Podhurst, Orsetk P.A. as of April 17, 2009' ![](_page_19_Picture_5.jpeg) We will wpplement this list as necessary. # EXHIBIT C to Plaintiffs Jane Doe 101 and Jane Doe 102's Motion For No-Contact Order ### ROBERT C. JOSEFSBERG From: ROBERT C. JOSEFSBERG Sent: Monday, May 18, 2009 4:48 PM To: 'rcrit©bcfclaw.comi; jagesg@bellsouth.net Subject: Epstein No Contact Letter Importance: High Attachments: No Contact Letter of April 17.pdf Gentlemen: On April 17, 2009 we sent your team the attached No Contact Letter. To date, we have not heard back from you or any other members of Mr. Epstein's defense team. If we don't hear back from you by Wednesday, May 20, 2009, we will seek relief in court. It you have any questions, please do not hesitate to contact us. Robert C. Josefsberg # EXHIBIT D to Plaintiffs Jane Doe 101 and Jane Doe 102's Motion for No-Contact Order ![](_page_23_Picture_288.jpeg) **BURMAN, CRITTON, LUTTIER\ & COLEMAN LLP** A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN, P.A.1\ GREGORY W. COLEMAN, P.A.1\ ROBBICK D. CRITTON, JR., P.A.1\ BERNARD LEBEDEKER\ MARK T. LUTTIER, P.A.\ JEFFREY C. PEPPIN\ MICHAEL J. PICK\ HEATHER MONAMARA RUDA 1 FLORIDA BOARD CRITERIED\ CIVIL TRIAL LAWYER ADELQUI J. BENAVENTE\ PARALEGAL / INVESTIGATOR BARBARA M. McKENNA\ ASHLEB STOKEN-BARING\ BETTY STOKES\ PARALEGALS RITA H. BUDNYK\ OF COUNSEL May 18, 2009 Katherine W. Ezell, Esq.\ Robert Josefsberg, Esq.\ Podhurst Orseck, P.A.\ 25 West Flagler Street, Suite 800\ Miami, FL 33130 Re: [REDACTED] Dear Kathy and Bob: [REDACTED] Additionally, Bob, you wrote a letter on April 17, 2009 stating your position regarding "No Contact" with any of your firm's clients based on your interpretation of the Non-Prosecution Agreement. I do not concede that your position is correct nor that the Non-Prosecution Agreement prevents some forms of contact with your clients. [REDACTED] [REDACTED] [REDACTED] [REDACTED] L • A • W • Y • E • R • S May 18, 2009\ Page 2 [REDACTED] Cordially yours, ![](<>)RDC/clz cc: Jack Goldberger, Esq. b7D # EXHIBIT E to Plaintiffs Jane Doe 101 and Jane Doe 102's Motion for No-Contact Order 1. MICHAEL BURMAN, P.A., GREGORY W. COLEMAN. PA. ROBERT D CRIITON.A. RAJ BERNARD LEBEDEKER MARK T LUTTIBR. PA. JEFFREY C. PEON MICHAEL). PIKE HEATHER IkNAMARA RUDA Maim DOARDCOMMSD °VILMA,. LAMM ![](_page_26_Picture_2.jpeg) # BURMAN, CRITTON, LUTTIER & COLEMAN LLP ALIMITED LIABILITY PARTNERSHIP ## Sent by E-Mall and U.S. Mail Robert C. Josefsberg, Esq. Katherine Ezell, Esq. Podhurst Orseck, PA. 25West Flagler Street, Suite 800 Miami, FL 33130 Dear Bob: May 21, 2009 ADELQUIJ BENAVENTE PAIIALECIAL I 0NE311OATOR BARBARA M. McKENNA ASHUB STOKEN•BARDA3 BETTY STOKES PARALEGALS RITA IL BUDNYK CeCotaNa. As I advised you yesterday, I am responding to your April 17, 2009 letter. As I stated in my e-mail, I think your request is unnecessary. Despite what Roy may have said to you, my client has had no contact with any of your clients. To my knowledge, the only one who has "breached" any agreement regarding contact Is your own client, awho, as I advised you in a letter last week, contacted Jack Goldberger's her. office looking for her settlement check. Mr. Goldberger, of course, did not speak with Professional Lawyers who represent Mr. Epstein are well familiar with the Rules of equally Conduct, including Rule 4-4.2. At the same time, I am certain you are familiar with that Rule. The Comment provides "Parties to a matter may communicate directly with each other...". attorneys To who my knowledge, neither Mr. Epstein nor any attorney or agent of those represent Mr. Epstein, have contacted or attempted to contact your clients. Given that it is not Mr. Epstein's Intention to have direct contact with your counsel. clients, it is unnecessary to respond point by point to statements attributed to my co- L•A•W•Y•E'R'S May 21, 2009 Page 2 Rather than to be concerned about what my client is doing, I would ask that you advise your clients not to contact Mr. Epstein's lawyers directly. Neither I nor the attorneys who represent Mr. Epstein want to be put in a position where we are set up by any of your clients. ![](<>)![](<>)RDC/msc cc: Roy Black, Esq.\ Jay Lefkowitz, Esq.\ J. Michael Burman, Esq.\ Jack Goldberger, Esq. Josefsberg.011.doc ### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRAMM Plaintiff vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff; vs. JEFFREY EPSTEIN, Defendant. , JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80232-MARIZAIMM CASE NO.: 08-CV-80380-MARRAIMM JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARRAM. Plaintiff; VS. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARItAt= Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 7, CASE NO.: 08-CV-80993-MARRA/MMI Plaintiff, vs. JEFFREY EPSTEIN, Defendant. C.M.A., CASE NO.: 08-CV-80811-MARRAUM Plaintiff, vs. JEFFREY EPSTEIN, Defendant JANE DOE, CASE NO.: 08-CV-80893-MARRAJ Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. II, CASE NO.: 08-CV-80469-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE. NO. 101, CASE NO.: 09-CV-80591-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 102, CASE NO.: 09-CV-80656-MARRA/JOffNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant #### ORDER THIS CAUSE comes before the Court on Plaintiffs' Motion for No-Contact Order (DE #\_J, filed May 22, 2009. Plaintiffs represent that Defendant has not agreed to the relief