Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE & TO OVERRULE OBJECTIONS. & FOR AN AWARD OF DEFENDANT'S REASONABLE EXPENSES Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, moves this Court for an order compelling Plaintiff, JANE DOE No. 2 To respond to specified production requests and to overrule her objections asserted in Plaintiffs Responses To Defendant's First Request To Produce, dated January 26, 2009. Defendant further seeks an award of his reasonable expenses, including expenses, associated with the making of this motion. Rule 37, Fed.R.Civ.P. (2008); Local Gen. Rules 7.1 and 26.1 H (S.D. Fla. 2008). In support of his motion, Defendant states: Introduction Prior to the filing of this motion, counsel for Defendant and counsel for Plaintiff corresponded with each other and were able to resolve some of the discovery issues related to Defendant's First Request to Produce and Plaintiffs Response thereto. By letter, dated March 3, 2009, the Plaintiff agreed to withdraw her "General Objections" set forth in her response. As well, issues as to production request no. 14 are presently EFTA00221691