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Case 9:09-cv-80802-KAM Document 11 Entered on FLSD Docket 08/11/2009 Page 1 of 3

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 09-CV-80802-MARRA/JOHNSON

JANE DOE NO. 8,

Plaintiff,

vs.

JEFFREY EPSTEIN,

Defendant.
____________________________________/

PLAINTIFF JANE DOE NO. 8'S UNOPPOSED MOTION
TO CONSOLIDATE FOR DISCOVERY PURPOSES

Plaintiff, Jane Doe No. 8, by and through undersigned counsel, files this Unopposed Motion
to Consolidate for Discovery Purposes, and states as follows:

1. This case involves the alleged sexual abuse of Jane Doe No. 8 in 2001 by Jeffrey
Epstein in Palm Beach, Florida.

2. The facts of this case arise from the same series of events as the multiple cases
pending in this Court against Jeffrey Epstein which are consolidated for purposes of discovery as
Jane Doe No. 2 v. Jeffrey Epstein, Case no. 08-CV-80119-Marra/Johnson.

3. It is anticipated by the parties that there will be a significant overlap in witnesses,
evidence, and depositions in this case and the consolidated proceedings.

4. Accordingly, Jane Doe No. 8 requests that this Court consolidate this case with Jane
Doe No. 2 v. Jeffrey Epstein, Case no. 08-CV-80119-Marra/Johnson and consolidated cases, for
purposes of discovery only and amend the caption of the consolidated cases accordingly.

5. Prior to the filing of this Motion, Plaintiff’s counsel conferred with Defendant’s

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Case 9:09-cv-80802-KAM Document 11 Entered on FLSD Docket 08/11/2009 Page 2 of 3

counsel, who advised that Defendant does not oppose the relief requested.

Dated: August 11, 2009.
Respectfully submitted,

By: s/ Adam D. Horowitz
Stuart S. Mermelstein (FL Bar No. 947245)
ssm@sexabuseattorney.com
Adam D. Horowitz (FL Bar No. 376980)
ahorowitz@sexabuseattorney.com
MERMELSTEIN & HOROWITZ, P.A.
Attorneys for Plaintiff Jane Doe 8
18205 Biscayne Blvd., Suite 2218
Miami, Florida 33160
Tel: 305-931-2200
Fax: 305-931-0877

CERTIFICATE OF SERVICE

I hereby certify that on August 11, 2009, I electronically filed the foregoing document with
the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
day to all parties on the attached Service List in the manner specified, either via transmission of
Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
parties who are not authorized to receive electronically Notices of Electronic Filing.

/s/ Adam D. Horowitz

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Case 9:09-cv-80802-KAM Document 11 Entered on FLSD Docket 08/11/2009 Page 3 of 3

SERVICE LIST
DOE vs. JEFFREY EPSTEIN
CASE NO.: 09-CV-80802-MARRA/JOHNSON
United States District Court, Southern District of Florida

Jack Alan Goldberger, Esq.
jgoldberger@agwpa.com

Robert D. Critton, Esq.
rcritton@bclclaw.com

/s/ Adam D. Horowitz

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