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Case 9:08-cv-80804-KAM Document 12 Entered on FLSD Docket 08/21/2008 Page 1 of 5
UNITED STATES DISTRlCT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-80804-CIV-MARRA/JOHNSON
JANE DOE, a/k/a,
JANE DOE NO. 1,
Plaintiff,
vs.
JEFFREY EPSTEIN, HALEY
ROBSON, and SARAH KELLEN, •
Defendants.
PLAINTIFF'S MOTION TO PRESERVE EVIDENCE
AND EXPEDITE. CERTAIN.DISCOVERY
Plaintiff Jane Doe moves, pursuant to Rules 26 an:d 34 to Preserve Evidence and Expedite
the Discovery of this Evidence and states:
1.. Defendants removed this action to federal court on July 21, 2008. (DE 1).
2. Plaintiff has filed a motion to remand on August 18, 2008. (D.E. 11).
3. It has come to the attention of Plaintiffs counsel that on July _21; 2008, Defendant
JEFFREY EPSTEIN filed a Motion with the Florida State Court to return the
evidence seized at his horne in conjunction with his criminal prosecutiofL (Ex. 1).
4. This evidence is relevant and critical to the prosecution of not only the insta:ntclaim,
but for six (6) other claims filed against Defendant EPSTEIN, including .but not
limited to the Florida RICO claims filed in State Court
WHEREFORE, Plaintiff respectfully request the. Court grant her Motion to Preserve· of
all of the seized Evidence identified in Ex. A, to Exhibit 1 of this Motion. (Palm Beach Police
Department Property Receipt) should it be Returned to EPSTEIN by the State Court, and
Case 9:08-cv-80804-KAM Document 12 Entered on FLSD Docket 08/21/2008 Page 2 of 5
expedite the duplication of this evidence immediately upon its return, in advance of any Rule 26
conference.
MEM0RANJ)UM0FLAW
Pursuant to Rules 26, 30 and 34, of the Fed
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