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Case 9:09-cv-80591-KAM Document 12 Entered on FLSD Docket 05/04/2009 Page 1 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-80591-MARRA/JOHNSON
JANE DOE No. 101,
Plaintiff,
V.
JEFFREY EPSTEIN,
Defendant,
-----------------''
DEFENDANT EPSTEIN'S RESPONSE IN OPPOSITION TO THIS COURT'S ORDER TO
SHOW CAUSE AS WHY ALL CASES SHOULD NOT BE CONSOLIDATED FOR DISCOVERY
PURPOSES AND MOTION TO CLARIFY THE COURT'S ORDER DATED APRIL 28, 2009
Defendant, JEFFERY EPSTEIN, (EPSTEIN), by and through his undersigned
attorneys, hereby files his Response in Opposition to this Court's Order to Show Cause
as to Why All Cases Should Not be Consolidated for Purposes of Discovery and Motion
for Clarification of this Court's Order on general consolidation of discovery (DE 6), and
states:
I. Response In Opposition
Defendant has no further objections to consolidating these cases for
purposes of depositions as outlined in this Court's April 28, 2009 Order.
However, to consolidate the cases for purposes of all "discovery" including, but
not limited to, motion practice and related orders thereto will, without question, confuse
many of the individual discovery issues raised not only by Epstein as to the individual
Plaintiffs that have brought separate lawsuits against him, but will also confuse the
Case 9:09-cv-80591-KAM Document 12 Entered on FLSD Docket 05/04/2009 Page 2 of 5
Page 2
individual discovery issues raised by those same individual Plaintiffs as to Epstein. This
will undoubtedly lead to several motions to clarify certain orders which will seek
explanation from the court as to how those orders affect Epstein as to each individual
Plaintiff's discovery requests and vice versa (i.e., how t
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