Case 9:09-cv-80591-KAM Document 14-1 Entered on FLSD Docket 05/06/2009 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Civil Action No. Plaintiff, vs. JEFFREY EP=, Defendant. MOTION TO PROCEED ANONYMOUSLY AND INCORPORATED MEMORANDUM OF LAW Plaintiff, Jane Doe No. 101, by and through her undersigned counsel, moves this Court to enter an Order granting Plaintiff permission to proceed in this action under the pseudonym "Jane Doe No. 101" and, as grounds, states as follows: 1. As outlined in detail in the Complaint, Jane Doe No. 101 was sexually abused by Defendant, Jeffrey Epstein, when she was under the age of 18. 2. As a result of Defendant's sexual abuse, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. 3. Disclosure of Plaintiff's name would cause her much additional embarrassment, humiliation, and psychological trauma. Podhurst Orseck, P.A. 25 West Hagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 3(6.358.2382 • Fort Lauderdale 554.463.4346 www.podlunitcons EFTA02738205