Case 9:08-cv-80119-KAM Document 66 Entered on FLSD Docket 03y26/2009 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO. 3, MOTION TO CONSOLIDATE CASES FOR PURPOSES OF DISCOVERY, AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT Non-party witness, Jane Doe No. 3, by and through undersigned counsel, files this Motion for Protective Order and to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate Cases for Purposes of Discovery, and Memorandum of Law in Support, as follows: I. Introduction This is one of six (6) related cases in this Court against Defendant Jeffrey Epstein, each alleging that the Defendant sexually assaulted the plaintiff when she was a minor. This Motion is prompted by the Defendant's efforts to take the deposition of Jane Doe No. 3 as a witness in this case. Defendant, however, does not at this time seek to take Jane Doe No. 3's deposition in her own case. The Defendant apparently intends to take Jane Doe No. 3's deposition at least twice, and as discussed below, most likely three times. Plaintiff Jane Doe No. 3 alleges that she is a victim of sexual assault by Defendant Epstein. To compel her to sit for deposition by Epstein's attorney more than once would be unduly traumatizing, burdensome, annoying, harassing and, most importantly, unnecessary. There is no - 1 - EFTA00221676