IN THE COURT OF THE FIFTEENTH

EFTA02729648

Case 9:08-cv-80804-KAM

Case 9:08-cv-80804-KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a JANE DOE #1, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. EPSTEIN'S RESPONSE TO MOTION TO PRESERVE EVIDENCE [DE 121 Defendant Jeffrey Epstein hereby responds to the plaintiff Jane Doe's motion to preserve evidence, as follows: I. The Certificate of Compliance annexed to the plaintiffs motion states that plaintiff's "counsel conferred with counsel for [Mr. Epstein] . . . and [Epstein's] counsel advised that [Epstein] opposelS] this motion." DE 12 at 2 (emphasis added). That certification is inaccurate. 2. On August 21, 2008, counsel for the plaintiff called Kathryn Meyers, Esq. of the Lewis Tein law firm to elicit Epstein's position on this motion. Ms. Meyers responded that she would confer with Mr. Tein and call them back. Less than thirty minutes later, however, plain

Case 9:08-cv-80804-KAM

Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 1 of 100 nsor & Associates RepornnE sad Transcripoon. Inc 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 75 Q. Because Mr. Epstein never came to your dad's house, correct? A. Correct. Q. And no one who worked for Mr. Epstein ever did something to your dad's tires, did they? MR. LEOPOLD: Objection. Lack of foundation, predicate. Don't guess. BY MR. TEIN: Q. It's not true that Mr. Epstein almost killed your father, is it? MR. LEOPOLD: Objection. Asked and answered, lack of foundation, predicate. BY MR. TEIN: Q. You can answer. A. No. Q. Now you told the police that you didn't know who was in the car with you and IIIIIII on the day you went to Epstein's house, didn't you? A. Yes. Q. And that was a lie, wasn't it? A. It's the truth. Q. You told the police that there was someone in the car next to you and you specifically said y

EFTA02728716

Crw4.-ta. \-2 •

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07'13'2009 Page 1 of 24 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. JANE DOE NO. 5, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-cv-80119-MARRA/JOHNSON CASE NO.: 08-CV-80232-MARRA/JOFINSON CASE NO.: 08-CV-80380-MARRA/JOHNSON CASE NO.: 08-CV-80381-MARRA/JOHNSON EFTA00221929 Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07/13/2009 Page 2 of 24 Jane Doe v. Epstein Case No. 08-CV-80893-Marra/Johnson Epstein's Memorandum of Law in Opposition to Jane Doe's Injunction Motion Page 2 of 24 CASE NO.: 08-80994-CIV-MARRA/JOHNSON JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE DOE NO. 7, Plaintiff, JEFFREY EPSTEIN Defendant. C.M.A., CASE N