UNITED S-5TATES DISTRICT C-4O-4URT SOUT-5HER-4N1 DISTRIC-4T OF FL-5OR-4IDA JANE DOE NO 2747CASE NO Pl-3ai-3nti-3ff vs JEFFREY E-5PSTEIN Defendant JANE DOE NO 2747CASE NO Pl-3ai-3nti-3ff vs JEFFREY E-5PSTEIN Defendant JANE DOE NO 2747CASE NO Pl-3ai-3nti-3ff vs JEFFREY E-5PSTEIN Defendant JANE DOE NO 2747CASE NO Pl-3ai-3nti-3ff vs JEFFREY E-5PSTEIN Defendant Case Document Entered on FLSD Docket Page of JANE DOE NO 2747CASE NO Pl-3ai-3nti-3ff vs JEFFREY E-5PSTEIN Defendant JANE DOE NO 2747CASE NO CV-80993-MARRA/JOHNSON Pl-3ai-3nti-3ff vs JEFFREY E-5PSTEIN Defendant C.M.A CASE 2750-MARRA/JOHNSON Pl-3ai-3nti-3ff vs JEFFREY E-5PSTEIN Defendant JANE CASE 2750CV-80893-MARRA/JOHNSON Pl-3ai-3nti-3ff vs JEFFREY EPSTEIN et al Defendant DOE CASE 275080469-MARRA/JOHNSON Case Document Entered on FLSD Docket Page of Pl-3ai-3nti-3ff vs JEFFREY E-4PSTEIN et al Defendant JANE DOE NO 2747CASE NO CV-80591-MARRA/JOHNSON Pl-3ai-3nti-3ff vs JEFFREY E-5PSTEIN Defendant JANE DOE NO 2747CASE NO CV-80656-MARRA/JOHNSON Pl-3ai-3nti-3ff vs JEFFREY E-5PSTEIN Defendant PLAINTIFFS JANE DOES NOTI CE O-8F JOINDE-4R IN PL-4AINTIFFS JANE DOES AND 2S MOTION FOR NO-CONTACT ORDER 2535Plaintiffs Jane Does join in Plai ntiffs Jane Does and 2s Motion for No Contact Order filed May and state as follows Plaintiffs Jane Does incorporate a nd adopt the facts set forth in the pending Motion f4o1r No-Contact Order Addition6ally P7l4aint if4f4s1 off4er additiona5l f4acts in sup6port of4 the Motion for a No-Contact Order as set forth below Upon inform8ation and belief Plaintiffs Ja ne Does were all identified on the victim8s list provided to Defenda nt Epstein6 co6unsel in co6nn ection with the Non-prosecution Agreem9ent and each has been id6entified as vi ctim9s to Defendant Epstein in their pend6in6g Case Document Entered on FLSD Docket Page of action6s In June Palm8 Beach Circuit Cou6r-1t Judge Pucillo ord6e-1red Defendant Epstein to have any contact direct or 3indirect with any of his victim Judge Pucillo clarified that forbidden 223indirect contact in cluded but was not lim8ited to text m8e-1ss-5ages em8ails telephone calls or m8e-1ssages through third parties As de tailed herein Jane Does and have been contacted o6n1 m9u1ltiple o6ccasions by at least one person rep5r-2esenting that she is cooperating with5 and comm8unicating on behalf of Defendant Epstein In these contacts the Plaintiffs/victim8s-5 were threatened and harassed As with other Plaintiffs Jane Does a nd we-6re first introduced to Defendant Epstein by Hayley Robson ho was a high school friend Robson had had contact with these Plainti ffs on several occasions in w8h1ich she represented to Plaintiffs Jane Doe and that she is coo5perating with Defendant Epstein attorneys and that she is being financially supported by De fendant Epstein Moreover Robson has told thes5e Plain6tiffs specifically that she is communicating on behalf of Defendant Epstein During th6es5e contacts Robson m7a-7de disparaging comm ents to the5 Plaintif4f4s and also sent disturbing text m8e-1ssage to Jane Doe No In one text Robson specifically stated just m8e-1t with m8y1 lawyer today and I 2m finally done with the Epstein case LOL I knew you were suing Jeffrey all along and I 2ve learned so m8uch about you in the m8e-1antim8e LOL Jane Doe understood this to m8ean that obson had exchanged pr ivate inform8ation about Jane Doe with Defendant Epstein and his attorn eys Since February Jane Doe has continued to receive text m8e-1ssages from8 Robson that are som8e-1ti-7m8e-1s ha rassing and other tim8es seek information about Jane Doe 2s private life her lawsuit against De4fendant Epstein and/or her lawyer 2s strategy Ms Robson was named in at least one civil case against Mr Epstei n5 as a co-defendant See Jane Doe Epstein case no Palm Beach County Circuit Court Ms.5 Robson brought m8ultiple underage g5i-2rls to Epstein in addition5 to Jane Does and Case Document Entered on FLSD Docket Page of On one occ-6a-1sion Robson approached Jane Doe and disclosed that she was cooperating with Defendant Epstein 2s defense 2and that she Robson ag reed that she would testify against Jane Doe and the other plaintiffs to m9ake sure that non6e of the Plaintiffs ever received any m8oney fr-7om8 Defenda-6nt Epstein m8a-1king clear that her testim8ony would not be truthful to achieve this end Sh also m8a-1de disparaging comm8ents to Jane Doe accusing her of ruining Defendant Epstein 2s reputation The very possibility of any contact with Epstein or his agents including Robson causes anxiety and distress particularly to Jane Do and as well as the other Plaintiffs A no contact order should prevent further harassm8e-6nt of the Plaintiffs by Ep stein and his agents including but not lim8ited to Hayley Robson WHEREFORE Plaintif8fs Jane Does respec tf4ully join Plaintif4f4s Jane Does and6 in m8oving this Court to ente an order granting P6l-2aintif8fs Motion for a No Contact Order prohibiting the Defendant Jeffrey Epstein from any contact or communication with Plaintiffs either directly or indirectly except through Plain tiffs attorneys of record for the duration of the Order Dated June Respectfully6 subm8itted By Adam8 Horowitz 2750Stuart Merm8elstein F7L Bar No ssm8 sexabuseattorney.com Horowitz FL Bar No ahorowitz 6sexabuseattorney.com 2750MERMELSTEIN HOROW9I-2TZ P.A 2750Attorney5s fo6r Plaintiffs Biscayne Blvd Suite 2750Miam8i Florida Case Document Entered on FLSD Docket Page of CER4T1IFI4C4ATE OF S5E6RV4ICE I HEREBY CERTIFY t-7hat on June I el ectronically filed the foregoing docum8ent-7 with the Clerk of the Court using C7M/ECF I 5also certify that the foregoing docum8ent is being served this day to all parties on the attach6ed Se rvice Lis5t4 in the m9anner specified either via10 transm8ission of Notices of Electronic Filing gene rated by CM/ECF or in som8e-1 other authorized m8a-1nner for those parties who are not authorized to receive electronically Notices o6f4 Electronic5 Filing Ada-6m8 Horowitz Case Document Entered on FLSD Docket Page of SERVI-7CE LIST DOE vs JEFFREY EPSTEIN United States District Court Southern District of Flo5r-1id7a Jack Alan Goldberger E6s-1q jgoldberger agwpa.com Robert Critton Esq rcritton bclclaw.com Bradley Jam8e-1s Edwards bedwards rra-law.com Isidro Manu6el Garc5ia isidrog6arc5ia5 bellsou6th.6n1et Jack Patr4ick Hill jph searcylaw.com Katherine Warthen Ezell KEzell podhurst.com Michael Jam8e-1s Pike MPike bclclaw.com Paul Cassell cassellp law.utah.edu Richard Horace W9illits lawyerwillits aol.com Robert Josefsberg rjosefsberg podhurst.com Ada-6m8 Horowitz Case Document Entered on FLSD Docket Page of
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