Case Document Entered on FLSD Docket Page of JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80119-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80232-MARRA/JOHNSON I CASE NO 08-CV-80380-MARRA/JOHNSON JANE DOE NO Plaintiff CASE NO 08-CV-80381-MARRA/JOHNSON Case Document Entered on FLSD Docket Page of vs JEFFREY EPSTEIN Defendant JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80994-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80993-MARRA/JOHNSON C.M.A Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80811-MARRA/JOHNSON Case Document Entered on FLSD Docket Page of JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80893-MARRNJOHNSON JANE DOE NO II Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80469-MARRNJOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 09-CV-80591-MARRNJOHNSON JANE DOE NO Plaintiff VS CASE NO 09-CV-80656-MARRNJOHNSON Case Document Entered on FLSD Docket Page of JEFFREY EPSTEIN Defendant ORDER THIS CAUSE comes before the Court on Plaintiffs Jane Doe No and Jane Doe No Motion for an Order for the Preservation of Evidence and Incorporated Memorandum of Law DE filed May and this courts order DE The parties having agreed and the Court having carefully considered the motion and being otherwise fully advised in the premises It is ORDERED AND ADJUDGED that Plaintiffs Motion DE is GRANTED as follows Defendant Jeffrey Epstein and such employees and agents currently under his control and his attorneys are directed to take every reasonable step to preserve any evidence resulting from the October search of his home as set forth in this Courts order DE DE in Case previously entered Defendant Jeffrey Epstein and such employees and agents currently under his control and his attorneys are directed to take every reasonable step to preserve any evidence relevant to these cases that have been filed in federal court or that may lead to the discovery of admissible evidence relevant to these cases which includes documents data and tangible things including writings records files correspondence digital or chemical process photographs including negatives reports memoranda calendars diaries minutes electronic messages voicemail mail telephone message records or logs computer and network activity logs hard drives Case Document Entered on FLSD Docket Page of backup data removable computer storage media such as tapes disks and cards printouts document image files web pages databases spreadsheets software books ledgers journals orders invoices bills vouchers checks statements worksheets summaries compilations computations charts diagrams graphic presentations drawings films charts video phonographic tape or digital recordings or transcripts thereof drafts jottings and notes Information that serves to identify locate or link such material such as file inventories file folders and indices is also included Specifically Defendant must preserve the following evidence as defined herein records of phone communications records of domestic and international travel including travel in Defendants private airplanes former and current employee records tax returns any document evidencing payment by Defendant of U.S currency and/or merchandise to each person on the list provided by the United States Attorneys Office USAO list any evidence stored in Defendants storage unit all photographs of the interior and exterior ofDefenda11ts Palm Beach residence as it appeared in through October any diary log memo pad calendar or other writing which reflected the date that each person on the USAO list visited Defendants residence any diary or document wherein each person on the USAO list wrote regarding any visit to Defenda11ts residence all documents sent by the Palm Beach Police Department PBPD the FBI the USAO or the Palm Beach State Attorneys Office PBSAO to the defendant and all computers used by Defendant and/or such agents and employees currently under his control to the extent the computers have evidence relating to these cases The time period for the preservation of evidence shall be as it relates to Jane Doe and through October as it relates to other persons on the USAO list Case Document Entered on FLSD Docket Page of Evidence is defined as any document or information that is in the possession custody or control of the defendant as of the date of this order and that is relevant to these cases or that may lead to the discovery of evidence relevant to these cases The duty to preserve evidence extends to documents data and tangible things in the possession custody and/or control of Defendant Jeffrey Epstein and such employees or agents currently under his control or attorneys who possess materials reasonably anticipated to be subject to discovery in these actions Counsel for the Defendant shall be directly responsible only to the extent they are in possession or control of evidence Counsel shall provide a copy of this Order to the Defendant and to those employees or agents whom defense counsel knows or has reason to believe may have evidence Preservation is to be interpreted broadly to accomplish the goal of maintaining the integrity of all documents data and tangible things reasonably anticipated to be subject to discovery in these actions under Rules and of the Federal Rules of Civil Procedure If an objection or privilege is raised the parties may raise the issue with this Court in a timely fashion and shall preserve the evidence in question pending resolution by the Court An agreement to preserve evidence and this Order is not a waiver of any existing or future right to object to production or any constitutional or evidentiary basis The parties without leave of Court may agree in writing that certain documents or categories of evidence need not be preserved as otherwise required by this Order If such agreement is reached such agreement is effective upon signing and without further order of this Court Case Document Entered on FLSD Docket Page of If this Court determines that evidence has been wrongfully destroyed or lost in violation of this Order it may impose appropriate sanctions based upon motion and an evidentiary hearing if necessary Each party shall bear its own costs for complying with this Order DONE AND ORDERED in Chambers at West Palm Beach Palm Beach County Florida this of
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