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 MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO MARRA/JOHNSON JANE DOE NO CASE NO MARRA/JOHNSON Case Document Entered on FLSD Docket Page of Plaintiff vs JEFFREY EPSTEIN Defendant I JANE DOE NO Plaintiff vs JEFFREY EPSTEIN CASE NO MARRA/JOHNSON Defendant JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 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 JANE DOE NO II Plaintiff vs JEFFREY EPSTEIN Defendant JANE DOE NO IOI Plaintiff vs JEFFREY EPSTEIN Defendant JANE DOE NO Plaintiff CASE NO 08-CV-80893-MARRA/JOHNSON CASE NO MARRA/JOHNSON CASE NO MARRA/JOHNSON CASE NO MARRA/JOHNSON Case Document Entered on FLSD Docket Page of vs JEFFREY EPSTEIN Defendant PLAINTIFFS JANE DOE NO AND JANE DOE NO REPLY TO DEFENDANT JEFFREY EPSTEINS RESPONSE TO PLAINTIFFS JANE DOE NO AND JANE DOE NO MOTION FOR A NO CONTACT ORDER Plaintiffs JANE DOE No and JANE DOE No together the Plaintiffs by and through undersigned counsel hereby reply to Defendant Jeffrey Epsteins Response to Plaintiffs Jane Doe No and Jane Doe No Motion for a No-Contact Order Response as follows Plaintiffs have not and will not engage in any name-calling For purposes of Plaintiffs Jane Doe No and Jane Doe No Motion for a No Contact Order Motion it does not matter whether many of the alleged victims were or are admitted prostitutes dancers at strip clubs or have criminal records or warrants for their arrests Def Resp or whether they were living in a monastery or planning on becoming nuns lawyers or judges This matter is quite simple The allegations are that when these victims were minors Defendant sexually exploited abused molested and/or battered them Regardless of the victims character or Defendants character it is obvious that Defendant Jeffrey Epstein a 55-year-old designated sexual offender and convicted felon should have no contact with his victims Defendant makes much ado that one victim allegedly telephoned Jack Goldbergers office to complain that Mr Goldberger was holding up the matter Def.s Case Document Entered on FLSD Docket Page of Resp We have no reason to doubt the truth of that statement by defense counsel Unsurprisingly a 21-year-old homeless ill and desperate victim who had waited for settlement funds for seven weeks regretfully may have called Mr Goldbergers office but whether she did so has nothing to do with Plaintiffs Motion Likewise if Defendant attempts to telephone undersigned counsel to complain or have any other contact with undersigned counsel undersigned counsel will handle the matter as professionally as Jack Goldberger did by refusing to speak to the opposing party The troublesome part of Defendants position is his counsels statement in the attached correspondence that pursuant to Rule of the Rules of Professional Conduct parties to a matter may communicate directly with each other In this case Plaintiffs counsel are concerned that Defendant or his agents may assert that alleged right and we vehemently disagree that they should have that prerogative in these Plaintiffs cases No legal justification exists for Defendant or his agents to have any direct communications with victims whom Defendant Jeffrey Epstein sexually exploited abused molested and/or battered In his Response see Def Resp and in his letter counsel for Defendant Jeffrey Epstein professes that it is not Mr Epsteins intention to have any direct contact with our clients This statement poses two significant problems First it leaves the door open for Defendants investigator or other agent to contact the victims Such contact would not be direct and would not be inconsistent with his professed intention to refrain from direct contact with his victims See e.g Cook All State Home Mortgage Inc No WL at 6th Cir May intimidation of plaintiffs-loan officers with contentious relationship with defendant-mortgage company Case Document Entered on FLSD Docket Page of through threatening phone calls by defendants employees considered indirect contact in violation of no-contact order in civil suit claiming violation of Fair Labor Standards Act Commonwealth Butler N.E 2d Mass App Ct defendants anonymous delivery of flowers to victim considered indirect contact in violation of no contact order Second Defendants counsel does not state that Defendant will not have any contact with his victims He merely states Defendants intentions Unfortunately the last five months is replete with other incidents in which Defendant through his counsel has stated his intentions and thereafter changed his mind Defendant Jeffrey Epstein feels free-and actually is free-to change his mind and his stated intentions His victims deserve more than that Because they are traumatized and fearful they require for their security a firm unambiguous commitment that Defendant will not directly or indirectly contact either of them considering the situation any secure commitment is attainable only via a Court order Plaintiffs cannot emotionally afford to be in a position in which Defendant can unilaterally change his mind In the event that Defendant wants to be present at the deposition of a Plaintiff or at a Court hearing where a Plaintiff is to attend the Court can easily resolve such situations at that time Meanwhile the sole purpose of Defendants refusal to agree to not contact these Plaintiffs is to leave them intimidated and in fear of being in the presence of the man who has sexually exploited abused molested and/or battered them One would think that instead Defendant would have voluntarily agreed with Plaintiffs prior request to have no contact directly or indirectly including through his agents and would want to demonstrate to the Court that he will not contact his victims his refusal to stay away from them is nothing short of disturbing Case Document Entered on FLSD Docket Page of Although not requested if Defendants counsel seeks some type of reciprocity Plaintiffs counsel would agree in writing and would not oppose a Court order prohibiting Plaintiffs from contacting Defendant Jeffrey Epstein It is obvious to undersigned counsel that there should be absolutely no contact between the parties to these lawsuits WHEREFORE Plaintiffs request this Court to enter an Order prohibiting Defendant Jeffrey Epstein and/or his agents from directly or indirectly contacting them Dated June Respectfully submitted PODHURST ORSECK P.A Attorneys for Plaintiffs Jane Doe No and Jane Doe No By Robert Josefsberg Robert Josefsberg Fla Bar No riosefsberg podhurst.com Katherine Ezell Fla Bar No kezell podhurst.com City National Bank Building Flagler Street Ste Miami FL Telephone Facsimile Case Document Entered on FLSD Docket Page of CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this 4th day of June we electronically filed the foregoing document with the Clerk of the Court using CM/ECF We also certify that the foregoing document is being served this day on all counsel of record identified on the attached Service List either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing Respectfully submitted PODHURST ORSECK P.A Attorneys for Plaintiffs Jane Doe No and Jane Doe No By s/Katherine Ezell Robert Josefsberg Fla Bar No rjosefsberg podhurst.com Katherine Ezell Fla Bar No kezell podhurst.com City National Bank Building Flagler Street Ste Miami FL Telephone Facsimile Case Document Entered on FLSD Docket Page of SERVICE LIST JANE DOE NO JEFFREY EPSTEIN Case No 08-CV-80119-MARRA/JOHNSON United States District Court Southern District of Florida Robert Critton Esq Michael Pike Esq Burman Critton Luttier Coleman LLP North Flagler Drive Suite West Palm Beach FL Phone Fax rcrit bclclaw.com mpike bclclaw.com Counsel for Defendant Jeffrey Epstein Jack Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone Fax jagesg bellsouth.net Co-Counsel for Defendant Jeffrey Epstein Bruce Reinhart Esq Bruce Reinhart P.A South Australian Avenue Suite West Palm Beach FL Phone Fax ecf brucereinhartlaw.com Counsel for Co-Defendant Sarah Kellen Jack Scarola Esq Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax jsx searcylaw.com jph searcylaw.com Counsel for PlaintifJC.MA Case Document Entered on FLSD Docket Page of Adam Horowitz Esq Stuart Mermelstein Esq Mermelstein Horowitz P.A Biscayne Blvd Suite Miami FL Phone Fax ahorowitz sexabuseattomey.com smennelstein sexabuseattomey.com Counsel.for Plaintiffs in Related Case Nos Spencer Todd Kuvin Esq Theodore Jon Leopold Esq Leopold Kuvin P.A PGA Boulevard Suite Palm Beach Gardens FL Phone Fax skuvin leopoldkuvin.com tleopold leopoldkuvin.com Counsel for Plaintiff in Related Case No Richard Willits Esq Richard Willits P.A th Ave North Suite Lake Worth FL Phone Fax lawyerwillits aol.com reelrhw hotmail.com Counsel for Plaintiff in Related Case No Brad Edwards Esq Law Office of Brad Edwards Associates LLC Harrison Street Suite Hollywood FL Phone Fax bedwards rra-law.com be bradedwardslaw.com Counsel.for Plaintiff in Related Case No Isidro Manuel Garcia Esq Garcia Elkins Boehringer Case Document Entered on FLSD Docket Page of Datura Avenue Suite West Palm Beach FL Phone Fax isidrogarcia bellsouth.net Counsel for Plaintiff in Related Case No
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