## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 09-CIV- 80469 — MARRA.

JANE DOE H,

Plaintiff,

v.

JEFFREY EPSTEIN,

Defendant.

## NOTICE OF RELIANCE ON AND INCORPORATION OF DEFENDANT'S REPLY (DE 31) TO PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT'S MOTION TO DISMISS(DE 20 & 36)

Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, hereby gives notice of his intent to rely on and incorporate hereon Defendant's Reply to Plaintiff's Memorandum of Law in Opposition to Defendant's Motion to Dismiss:

- 1. Defendant, EPSTEIN, filed his Motion to Dismiss on May 9, 2009 (DE 13).
- 2. Plaintiff, Jane Doe II, filed her initial Memorandum of Law in Opposition to Defendant Epstein's Motion to Dismiss on May 22, 2009 (DE 20).
- 3. Defendant, EPSTEIN, filed his Reply to Plaintiff, Jane Doe II's, Memorandum of Law in Opposition to Defendant Epstein's Motion to Dismiss on June 1, 2009 (DE 31).
- 4. After a hearing on June 12, 2009, counsel for Plaintiff, Jane Doe II, stated he would withdraw certain claims in Plaintiff, Jane Doe II's initial Memorandum of Law in Opposition to Defendant Epstein's Motion to Dismiss (DE 20).

Jane Doe II v. Epstein, et al. Page 2

5. Therefore, Plaintiff, Jane Doe II, filed her Amended Memorandum of Law in Opposition to Defendant Epstein's Motion to Dismiss on June 12, 2009 (DE 36).

1. Based upon the forgoing, Defendant relies on his Reply to Plaintiff, Jane Doe II's, Memorandum of Law in Opposition to Defendant Epstein's Motion to Dismiss (DE 31) and incorporates same herein by reference as if same was filed in Reply to Plaintiff, Jane Doe II's, Amended Memorandum of Law in Opposition to Defendant Epstein's Motion to Dismiss (DE 36). Accordingly, Defendant, EPSTEIN, stands on those arguments set forth in DE 31 and, therefore, will not be filing an additional supplemental reply.

> By: ROBERT D. rcrit bcicl RITTON, JR., ESQ. Florida Bar o. 224162 • .w.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpikeebcIclaw.com

Jane Doe II v. Epstein, et al.\
Page 3

### Certificate of Service

I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following service list in the manner specified/via transmission of Notices of Electronic Filing generated by CM/ECF on this 9 day of June, 2009:

Isidro M. [REDACTED], Esq.\
[REDACTED] Law Firm, P.A.\
224 Datura Street, Suite 900\
West Palm Beach, FL 33401\
561-832-7732\
561-832-7137 F\
[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net)\
*Counsel for Plaintiff*

Jack Alan Goldberger, Esq.\
Atterbury Goldberger & Weiss, P.A.\
250 Australian Avenue South\
Suite 1400\
West Palm Beach, FL 33401-5012\
561-659-8300\
561-835-8691 Fax\
[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net)\
*Co-Counsel for Defendant Jeffrey Epstein*

Respectfully submitted,

![](<>)*(Co-counsel for Defendant Jeffrey Epstein)*