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Case 9:09-cv-80802-KAM Document 29 Entered on FLSD Docket 06/14/2010 Page 1 of 9
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CIV-80119-MARRA/JOHNSON
JANE DOE NO. 2,
Plaintiff,
vs. JUN f 4 2010
JEFFREY EPSTEIN,
Defendant.
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Related cases:
08-80232,08-08380,08-80381,08-80994,
08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
I
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Defendant, Jeffrey Epstein's Emergency Motion For Protective Order, Motion to
Quash and Motion for Attorneys' Fees, With Incorporated Memorandum Of Law
Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
undersigned attorneys, hereby files his Emergency Motion For Protective Order, Motion
to Quash and Motion for Attorneys' fees and Costs, With Incorporated Memorandum Of
Law. In support, Defendant states as follows:
1. As this Court is well aware, these cases have been consolidated for discovery.
However, on April 1, 2010, Plaintiffs counsel, Spencer Kuvin, filed C.L. v. Epstein,
Case No. 10-80447-cv-Marra/Johnson, and that case has not been consolidated with the
other related cases for purposes of discovery.
2. On April 20, 2010, Mr. Kuvin served Maritza Milagros Vasquez with a subpoena
for deposition, which is set to occur tomorrow. See Exhibit "A". However, this Notice
and subpoena for deposition must be stricken/quashed as Mr. Kuvin, on behalf of his
client, has failed to comply with Fed.R.Civ.P. 26 (d). That rule states, in pertinent part,
Case 9:09-cv-80802-KAM Document 29 Entered on FLS
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