Case 9:08-cv-80119-KAM Document 79 Entered on FLSD Docket 04'17'2009 Page 1 of 7 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 RESPONSE TO PLAINTIFF'S 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 Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, serves his Response to Plaintiff's 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 (hereinafter, the Motion"), with incorporated memorandum of law. In support, Defendant states: I. RESPONSE WITH INCORPORATED MEMORANDUM OF LAW AS TO REPOSITION OF JANE DOE. NO.3 AND MOTION TO CONSOLIDATE a. The Depositions Plaintiff, Jane Doe No. 2, filed this federal lawsuit against Defendant, Jeffrey Epstein. In another separate matter, a Plaintiff, Jane Doe, No. 3., filed her own separate lawsuit against Defendant, Jeffrey Epstein. Plaintiffs counsel represents all Jane Does in cases Jane Doe Nos. 2 through 7 before this court. EFTA00221711