Case 9:08-cv-80380-KAM Document 148 Entered on FLSD Docket 11/03/2009 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80380-MARRa JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE NO. 4'S MOTION FOR PROTECTIVE ORDER AS TO THE SCOPE OF INQUIRY AT THE DEPOSITIONS OF JANE DOE NO. 4'S PARENTS. AND INCORPORATED MEMORANDUM OF LAW Plaintiff, Jane Doe No. 4 ("Plaintiff"), by and through undersigned counsel, hereby files Plaintiff Jane Doe No. 4's Motion for Protective Order, pursuant to S.D.Fla.L.R. 7.1, and states as follows: 1. Counsel for Defendant Jeffrey Epstein have advised Plaintiffs' counsel that they intend to take the depositions of the mother and father of Jane Doe No. 4 within the next few weeks. Plaintiff does not oppose Defendant taking the depositions of her parents, but a protective order from this Court is necessary as to the scope of the inquiry into one particular discrete matter. 2. At Jane Doe No. 4's deposition on October 27, 2009, she testified that she has had abortions. She further testified that neither of her parents is aware that she has had abortions. At no time has she ever had any intention of disclosing the information about her abortions to her parents. Jane Doe No. 4 is presently 22 years old. EFTA02741337