Case 9:09-cv-80802-KAM Document 29 Entered on FLSD Docket 06/14/2010 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-C1V-80119-MAR/a JANE DOE NO. 2, Plaintiff, FILED by Vi vs. JUN 1 4 2010 JEFFREY EPSTEIN, STEVEN M. LARIMEnoCLERK U.S. Oisi CT S.D. OF FLA. - *pa: D.C. Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 Defendant, Jeffrey Epstein's Emergency Motion For Protective Order, Motion to Ouash and Motion for Attorneys' Fees, With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby files his Emergency Motion For Protective Order, Motion to Quash and Motion for Attorneys' fees and Costs, With Incorporated Memorandum Of Law. In support, Defendant states as follows: 1. As this Court is well aware, these cases have been consolidated for discovery. However, on April 1, 2010, Plaintiff's counsel, Spencer Kuvin, filed C.L. v. Epstein, Case No. 10-80447-cv-Marra_, and that case has not been consolidated with the other related cases for purposes of discovery. 2. On April 20, 2010, Mr. Kuvin served Maritza Milagros Vasquez with a subpoena for deposition, which is set to occur tomorrow. See Exhibit "A". However, this Notice and subpoena for deposition must be stricken/quashed as Mr. Kuvin, on behalf of his client, has failed to comply with Fed.R.Civ.P. 26 (d). That rule states, in pertinent part, EFTA02743466