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Case 9:09-cv-80469-KAM Document 76 Entered on FLSD Docket 05/28/2010 Page 1 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80119-MARRA/JOHNSON
JANE DOE NO. 2,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
____________________________________/
Related Cases:
08-80232, 08-80380, 08-80381, 08-80994,
08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092,
____________________________________/
PLAINTIFFS JANE DOES 2-8’ MEMORANDUM IN
RESPONSE TO DEFENDANT’S RULE 4 APPEAL
Plaintiffs, Jane Does 2-8 (“Plaintiffs”), by and through undersigned counsel, file this
Memorandum in Response to Defendant’s Rule 4 Appeal of the Magistrate Judge’s Orders (DE
480 and DE 513) directing Defendant to produce his income tax returns, as follows:
Introduction
Defendant appeals the Magistrate Judge’s Orders (DE 480 and DE 513) compelling
Defendant to produce income tax returns and related forms and schedules. He fails, however, to
demonstrate that the Magistrate Judge’s decision as to tax returns is clearly erroneous or contrary
to law. The applicable case law establishes that the tax returns are not protected from discovery
by the Fifth Amendment privilege under the act of production doctrine, or alternatively, that they
fall within the “required records” exception to the Fifth Amendment privilege.
The tax returns are indisputably relevant in these cases, particularly as to Plaintiff’s
claims for punitive damages, and given the Defendant’s invocation of the Fifth Amendment in
Case 9:09-cv-80469-KAM Document 76 Entered on FLSD Docket 05/28/2010 Page 2 of 10
blanket fashion to all requests for net worth discovery, there is a compelling need
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