Case 9:08-cv-80232-KAM Document 58 Entered on FLSD Docket 03/26/2009 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80232-MARRA I JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. MOTION FOR PROTECTIVE ORDER AGAINST PIECEMEAL DEPOSITIONS OF JANE DOE NO. 3, MOTION TO CONSOLIDATE CASES FOR PURPOSES OF DISCOVERY, AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT Plaintiff, Jane Doe No. 3, by and through undersigned counsel, files this Motion for Protective Order Against Piecemeal Depositions 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 in that case when she was a minor. This Motion is prompted by the Defendant's efforts to take the deposition of Plaintiff Jane Doe No. 3 as a witness in the related case, Jane Doe No. 2 v. Epstein, case no. 08-CV-80119-Marra. 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 -1- EFTA02739664