Case 9:08-cv-80893-KAM Document 214 Entered on F LSD Docket 09/02/2010 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN DOCUMENTS WITH INTEGRATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to a Joint Stipulation Regarding Certain Documentation files this his Motion for Protective Order and Objection to Disclosure of Certain Correspondence and Discovery for the reasons set forth below: I. PRELIMINARY STATEMENT During the underlying litigation, Epstein vigorously sought protection from the Court that these and other documents produced would be used for purposes other than those contemplated by the Federal Rules of Civil Procedure for discovery; i.e., dissemination in the media. His rights to contest this type of use were preserved as part of the settlement of these proceedings, which provided for confidentiality of the settlement as well as provisions to bring these matters to a close. Now, the fears that led to Epstein's efforts to seek protection from the court have now come to pass. The intended use of these documents is now leading to more litigation that the settlement of these cases was designed to end. Epstein requests that the court grant protection so that this does not occur. FOWL2R WHIT% BURNRIT, PA. • hiu.lin POINT - WIST TOW RR, SUMS Vol , 777 SOUTH FLN3L8R DRIVE, WRST PALM B6601, FLORIDA 37401 • (561)802-9044 EFTA00213902