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Case 9:09-cv-80591-KAM Document 14-1 Entered on FLSD Docket 05/06/2009 Page 1 of 5
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
JANE DOE No. I 01,
Civil Action No.
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
MOTION TO PROCEED ANONYMOUSLY
AND INCORPORATED MEMORANDUM OF LAW
Plaintiff, Jane Doe No. 101, by and through her undersigned counsel, moves this Court to
enter an Order granting Plaintiff permission to proceed in this action under the pseudonym "Jane
Doe No. 101" and, as grounds, states as follows:
I. As outlined in detail in the Complaint, Jane Doe No. 101 was sexually abused by
Defendant, Jeffrey Epstein, when she was under the age of 18.
2. As a result of Defendant's sexual abuse, Plaintiff has in the past suffered, and will
in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or
psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational
oppottunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages
associated with Defendant's manipulating and leading her into a perverse and unhealthy way of
life.
3. Disclosure of Plaintiffs name would cause her much additional embarrassment,
humiliation, and psychological tratuna.
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358,2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 14-1 Entered on FLSD Docket 05/06/2009 Page 2 of 5
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