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Case 9:09-cv-80656-KAM Document 5 Entered on FLSD Docket 05/11/2009 Page 1 of 12




                               UNITED STATES DISTRICT COURT
                               SOUTHERN DISTRICT OF FLORIDA

                               CASE NO.: 09-80656-CIV-Ryskamp

     JANE DOE No. 102,

                          Plaintiff,
     V.

     JEFFREY EPSTEIN,

                           Defendant,
     _______________,/

          RESPONSE IN OPPOSITION TO MOTION TO PROCEED ANONYMOUSLY

                                            AND

       EPSTEIN'S MOTION TO COMPEL AND/OR IDENTIFY JANE DOE #102 IN
      THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE #102 IN
        THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY. WITH
                   INCORPORATED MEMORANDUM OF LAW

             Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and

     through his undersigned attorneys, hereby files his Response In Opposition to

     Plaintiff, Jane Doe #102's Motion to Proceed Anonymously and files his Motion

     requesting that this Court enter an order identifying in the style of this case the

     complete legal name of the Plaintiff, JANE DOE #102 ("JANE DOE"), to

     substitute her complete legal name in this case in place of "JANE DOE" and,

     equally important, allowing Defendant to identify her in various subpoenas that

     Epstein must serve so Epstein can defend this case. In support, Mr. Epstein

     states as follows:




                                                                                       1
Case 9:09-cv-80656-KAM Document 5 Entered on FLSD Docket 05/11/2009 Page 2 of 12




       I. Response In Opposition With Incorporated Motion And Incorporated
                               Memorandum Of Law

                                   a.     Background

           1.     On May 1, 2009, Plaintiff filed this action against Epstein. The

     Complaint (DE 1) alleges three causes of action against him: Count I - Coercion



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