Case 9:10-cv-80447-KAM Document 12 Entered on FLSD Docket 06/14/2010 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-80447-CIV-Marra/Johns FILED C.L., by DC JUN 14 2010 Plaintiff, VS. STEVEN M. LARIMORE CLERK U.S. DIST. CT. S.D. OF FLA. • W.P.B. JEFFREY EPSTEIN, Defendant. Defendant, Jeffrey Epstein's Emergency Motion For Protective Order, Motion to Quash and Motion for Attorneys' Fees, With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby files his Emergency Motion For Protective Order, Motion to Quash and Motion for Attorneys' fees and Costs, With Incorporated Memorandum Of Law. In support, Defendant states as follows: 1. As this Court is well aware, these cases have been consolidated for discovery. However, on April 1, 2010, Plaintiff's counsel, Spencer Kuvin, filed C.L. v. Epstein, Case No. 10-80447-cv-Marra/Johnson, and that case has not been consolidated with the other related cases for purposes of discovery. 2. On April 20, 2010, Mr. Kuvin served Maritza Milagros Vasquez with a subpoena for deposition, which is set to occur tomorrow. See Exhibit "A". However, this Notice and subpoena for deposition must be stricken/quashed as Mr. Kuvin, on behalf of his client, has failed to comply with Fed.R.Civ.P. 26 (d). That rule states, in pertinent part, that: "[a] party may not seek discovery from any source before the parties have conferred as required by Rule 26(f). . . ." Mr. Kuvin, on behalf of his client, has not complied with Rule 26(f) and, therefore, the subpoena for deposition must be stricken/quashed and a Protective Order should be entered pursuant to Rule 26(c) forbidding the deposition from 1 EFTA02732383