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Case 9:08-cv-80069-KAM Document 5 Entered on FLSD Docket 01/29/2008 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-80069 CIV-MARRA/JOHNSON
JANE DOE NO.1, by and through
JANE DOE's FATHER as parent and natural
guardian, and JANE DOE's FATHER, and
JANE DOE's STEPMOTHER, individually,
Plaintiffs,
vs.
JEFFREY EPSTEIN,
Defendant.
----------------------'/
MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW
Applicant, JANE DOE'S MOTHER, individually and as parent and natural guardian of
JANE DOE NO. 1, by and through the undersigned counsel, moves this Court, pursuant to
Federal Rule of Civil Procedure 24(b), for leave to intervene as a plaintiff in this action in order
to assert the claims against Defendant JEFFREY EPSTEIN set forth in Applicant's proposed
complaint (attached hereto as EXHIBIT "A''). In support of this motion, Applicant states that:
1. Applicant has claims that share common questions of law or fact with the main action.
2. Applicant's motion to intervene is timely.
3. The original parties to this action will not be prejudiced by the intervention of Applicant.
4. Pursuant to Local Rule 7.1.A.3, counsel for Applicant, in a good faith attempt to resolve
this dispute, made a reasonable effort to confer with all parties who may be affected by
Case 9:08-cv-80069-KAM Document 5 Entered on FLSD Docket 01/29/2008 Page 2 of 3
her intervention in this action. Counsel for Applicant conferred with Counsel for JANE
DOE'S FATHER, who do not agree to her intervention in this action.
MEMORANDUM OF LAW
"'
Under Federal Rule of Civil Procedure 24(b)(l)(B), "[o]n timely motion, the court may
permit anyone to
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