Jeffrey_Epstein_Part_22_of_22_p0007.png

Case 9:08-cv-80119-KAM Document305 Entered on FLSD Docket 09/17/2009 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. / Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80581, 09-80656, 09-80802, 09-81092. / ( DEFENDANT’S, JEFFREY EPSTEIN, MOTION FOR SANCTIONS AND TO COMPEL DEPOSITION OF JANE DOE NO. 4 AND MEMORANDUM IN SUPPORT THEREOF Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, moves this court for an order granting sanctions pursuant to Rule 30(d)(2) and (3)(A) and (C) (referencing Rule 37(a)(5)), Federal Rules of Civil Procedure and compelling the deposition of Jane Doe No. ' 4 within fifteen (15) days and as grounds therefore would state: 1. On August 16, 2009, the deposition of Jane Doe No. 4 was noticed for September 16, 2009 to begin at 1:00 p.m. Plaintiffs counsel had advised that Jane Doe No. 4 could not appear for a deposition prior to that time of day, i.e. 1:00 p.m. 2. The deposition was originally set at the offices of the undersigned, but Plaintiff's _counsel requested that it be moved to the court reporter’s office. The court reporter is Prose Court Reporting located at 250 Australian ‘Avenue South, Suite 115, West Palm Beach, FL 33401. 03956-10985