Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 85 Entered on FLSD Docket 04/27'2009 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S REPLY MEMORANDUM IN SUPPORT OF MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA, AND MOTION TO CONSOLIDATE FOR PURPOSES OF DISCOVERY Plaintiff, by and through undersigned counsel, files this Reply Memorandum In Support of Motion for Protective Order, and to Quash Subpoena, and Motion to Consolidate for Purposes of Discovery, as follows: I. DEFENDANT FAILS TO SET FORTH ANY PREJUDICE OR CONFUSION THAT WOULD MILITATE AGAINST CONSOLIDATING THESE CASES FOR PURPOSES OF DISCOVERY In response to Plaintiffs' Motion to Consolidate, Defendant asserts that not all common issues of fact are present and the parties are not identical. These are not reasons to deny consolidation, particularly the limited consolidation for purposes of d