Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV-80119-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant Related cases Defendants Motion To Strike Declarations Attached And Cited In Plaintiffs Reply In Support Of Their Motion For Protective Order DE And Incorporated Memorandum Of Law Defendant Jeffrey Epstein hereinafter Epstein or Defendant by and through his undersigned attorneys respectfully moves this Court for an order Striking The Declarations attached to and cited in Plaintiffs Reply in Support of their Motion for Protective Order DE Local Rule allows for this court to strike same As good cause in support of granting the motion Defendant states On July Plaintiffs filed their Motion for Protective Order seeking to prevent any investigation of the Plaintiffs and/or the claims they assert against Jeffrey Epstein in their respective Complaints DE Plaintiffs Motion for Protective Order attached the Affidavits of Dr Kliman Ex A the Declaration of Jane Doe Ex and the Declaration of Jane Doe Ex Case Document Entered on FLSD Docket Page of On August Defendant filed his Response In Opposition to the above Motion for Protective Order DE On August Plaintiffs filed their Reply Memorandum in Support of Motion for Protective Order DE and attached and cited newly filed declarations for which Defendant does not have an opportunity to respond to under the rules Therefore the declarations delineated below are outside the scope of Plaintiffs initial Motion for Protective Order and the Defendants Response in Opposition Moreover the declarations are untimely In particular Plaintiffs attach to or cite in their Reply the declaration of Jane Doe dated August a newly filed declaration DE the declaration of Jane Doe a declaration not attached to the Reply or linked to any other motion by docket entry citation the declaration of Jane Doe a declaration not attached to the Reply and referenced as a new August declaration and the declaration of Jane Doe 4s sister Y.B.s newly filed declaration dated August DE Based upon the foregoing the Defendant does not have an opportunity to respond to the newly filed declarations or those declarations cited in the Reply but not attached or linked to any other motion To the extent Plaintiffs intention was to link the missing declarations to another motion response or reply previously filed by Plaintiffs same has not been specified in their Reply Note Defendant is not moving to strike the declaration of Jane Doe dated July because that declaration is attached to Plaintiffs initial motion Case Document Entered on FLSD Docket Page of Memorandum of Law Ivory Holme WL M.D Fla striking affidavits as untimely Wherefore Defendant respectfully requests that this court enter an order a striking the declaration of Jane Doe dated August a newly filed declaration DE striking the declaration of Jane Doe a declaration not attached to the Reply or linked to any other motion by docket entry citation striking the declaration of Jane Doe a declaration not attached to the Reply and referenced as a new August declaration the declaration of Jane Doe 4s sister Y.B.s newly filed declaration dated August DE or alternatively require Plaintiffs to file the missing declarations and allow Defendant days within which to file a Supplemental Brief addressing same and for such other and further relief as this court deems just and proper By c_ MICHAEL Pl ESQ Florida Bar Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all counsel of record identified on the follatg Srice List in the manner specified by CM/ECF on this ft.l day of Case Document Entered on FLSD Docket Page of ROBERT CRITTON JR ESQ Florida Bar No rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Flagler Drive Suite West Palm Beach FL Phone Fax Counsel for Defendant Jeffrey Epstein Certificate of Service Jane Doe No Jeffrey Epstein Case No 08-CV-80119-MARRA/JOHNSON Stuart Mermelstein Esq Adam Horowitz Esq Mermelstein Horowitz P.A Biscayne Boulevard Suite Miami FL Fax ssm sexabuseattorney.com ahorowitz sexabuseattorney.com Counsel for Plaintiffs In related Cases Nos Richard Horace Willits Esq Richard Willits P.A th Avenue North Suite Lake Worth FL Fax Counsel for Plaintiff in Related Case No reelrhw hotmail.com Brad Edwards Esq Rothstein Rosenfeldt Adler East Las Olas Boulevard Suite Fort Lauderdale FL Phone Fax bedwards rra-law.com Counsel for Plaintiff in Related Case No Paul Cassell Esq Pro Hae Vice South Room Salt Lake City UT Fax cassellp law.utah.edu Co-counsel for Plaintiff Jane Doe Isidro Garcia Esq Garcia Law Firm P.A Datura Street Suite West Palm Beach FL Case Document Entered on FLSD Docket Page of Jack Scarola Esq Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL Fax jsx searcylaw.com jph searcylaw.com Counsel for Plaintiff C.M.A Bruce Reinhart Esq Bruce Reinhart P.A Australian Avenue Suite West Palm Beach FL Fax ecf brucereinhartlaw.com Counsel for Defendant Sarah Kellen Theodore Leopold Esq Spencer Kuvin Esq Leopold Kuvin P.A PGA Blvd Suite Palm Beach Gardens FL Fax Counsel for Plaintiff in Related Case No isidrogarcia bellsouth.net Counsel for Plaintiff in Related Case No Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Fax rjosefsberg podhurst.com kezell podhurst.com Counsel for Plaintiffs in Related Cases Nos and Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jagesg bellsouth.net Counsel for Defendant Jeffrey Epstein
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