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Case 9:09-cv-80469-KAM Document 56 Entered on FLSD Docket 08/01/2009 Page 1 of 2

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 09-80469-Cr-Marra/Johnson

JANE DOE II,
Plaintiff,

vs.

JEFFREY EPSTEIN,
and SARAH KELLEN,
Defendants.
______________________/

MOTION TO ADOPT CO-DEFENDANT EPSTEIN’S
MOTION TO DISMISS AND REPLY

Defendant SARAH KELLEN, by and through undersigned counsel, respectfully requests

leave to adopt, as her own, co-defendant Jeffrey Epstein’s Motion to Dismiss and Reply and as

grounds states:

1. Plaintiff filed the instant action against Mr. Epstein and Ms. Kellen in March 2009.

2. On July 22, 2009, United States District Judge Kenneth L. Marra granted Ms. Kellen

leave until August 3, 2009, to file a responsive pleading in the instant action (DE 49).

3. By this Motion, Ms. Kellen seeks to file a responsive pleading in this action by

adopting as if set forth legally and factually by Ms. Kellen, co-defendant Jeffrey Epstein’s Motion

to Dismiss Plaintiff’s Complaint and Supporting Memorandum and Exhibits (DE 13), filed May 6,

2009, and co-defendant Jeffrey Epstein’s Reply in Opposition to Plaintiff’s Response in Opposition

to Epstein’s Motion to Dismiss (DE 31), filed June 1, 2009.

4. Ms. Kellen requests leave of the Court to adopt these motions as if they were her

own without burdening the record with a duplicative filing.

1
Case 9:09-cv-80469-KAM Document 56 Entered on FLSD Docket 08/01/2009 Page 2 of 2

WHEREFORE, Defendant Kellen respectfully requests this Court grant this Motion and

permit her to adopt co-defendant Jeffrey Epstein’s Motion to Dismiss Plaintiff’s Complaint

[…]