Court records
- Format
- Set
- Court Records
- Text
- Searchable
Text as released
Machine-read from the scan. Names, dates and numbers can be misread — check anything you rely on against the original page.
Case 9:08-cv-80804-KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-80804-CIV-MARRA/JOHNSON
JANE DOE, a/k/a
JANE DOE #1,
Plaintiff,
vs.
JEFFREY EPSTEIN, HALEY ROBSON,
and SARAH KELLEN,
Defendants.
_________________________________/
EPSTEIN’S RESPONSE TO
MOTION TO PRESERVE EVIDENCE [DE 12]
Defendant Jeffrey Epstein hereby responds to the plaintiff Jane Doe’s motion to preserve
evidence, as follows:
1. The Certificate of Compliance annexed to the plaintiff’s motion states that
plaintiff’s “counsel conferred with counsel for [Mr. Epstein] . . . and [Epstein’s] counsel advised
that [Epstein] oppose[s] this motion.” DE 12 at 2 (emphasis added). That certification is
inaccurate.
2. On August 21, 2008, counsel for the plaintiff called Kathryn Meyers, Esq. of the
Lewis Tein law firm to elicit Epstein’s position on this motion. Ms. Meyers responded that she
would confer with Mr. Tein and call them back. Less than thirty minutes later, however,
plaintiff’s counsel - - without waiting to hear back from us - - electronically filed the motion,
incorrectly certifying that we had actually opposed it.
3. Upon receipt of the motion via CM/ECF, Ms. Meyers immediately notified
plaintiff’s counsel of their error. Plaintiff’s counsel did not notify the court of the incorrect
Case 9:08-cv-80804-KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 2 of 4
certification, leaving the Court with the impression that Epstein opposed the motion and perhaps
prompting the Court to order an expedited response.
4. In fact, Epstein has no opposition to the relief requested.
5. It is worth noting that the motio
[…]