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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

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