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EFTA02742081

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Case 9:08-cv-80381-KAM Document 80 Entered on FLSD Docket 05/04/2009 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80381-MARRAIIMI JANE DOE NO. 5, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE IN OPPOSITION TO THIS COURTS ORDER TO SHOW CAUSE AS WHY ALL CASES SHOULD NOT BE CONSOLIDATED FOR DISCOVERY PURPOSES AND MOTION TO CLARIFY THE COURT'S ORDER DATED APRIL 28. 2009 Defendant, JEFFERY EPSTEIN, (EPSTEIN), by and through his undersigned attorneys, hereby files his Response in Opposition to this Court's Order to Show Cause as to Why All Cases Should Not be Consolidated for Purposes of Discovery and Motion for Clarification of this Court's Order on general consolidation of discovery (DE 78), and states: I. Response In Opposition Defendant has no further objections to consolidating these cases for purposes of depositions as outlined in this Court's April 28, 2009 Order. However, to consolidate the cases for purposes of all "discovery" including, but not limited to, motion practice and related orders thereto will, without question, confuse many of the individual discovery issues raised not only by Epstein as to the individual Plaintiffs that have brought separate lawsuits against him, but will also confuse the individual discovery issues raised by those same individual Plaintiffs as to Epstein. This will undoubtedly lead to several motions to clarify certain orders which will seek EFTA02742081

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