Case 9:08-cv-80232-KAM Document 70 Entered on FLSD Docket 04/17/2009 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80232-MARRA-Ma JANE DOE NO.3, Plaintiff, v. JEFFREY EPSTEIN, Defendant. / DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S 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 Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, serves his Response to Plaintiff's 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 (hereinafter, the Motion"), with incorporated memorandum of law. In support, Defendant states: I. RESPONSE WITH INCORPORATED MEMORANDUM OF LAW AS TO DEPOSITION OF JANE DOE. NO.3 AND MOTION TO CONSOLIDATE a. The Depositions Plaintiff, Jane Doe No. 3, filed this federal lawsuit against Defendant, Jeffrey Epstein. In other separate matters, Plaintiffs, Jane Does, Nos. 2, 4-7, filed their own separate lawsuits against Defendant, Jeffrey Epstein. Plaintiff's counsel represents all Jane Does in cases Jane Doe Nos. 2 through 7 before this court. EFTA02739777