EFTA02744406

Extracted Text #

Case 9:08-cv-80119-KAM Document 114-3 Entered on FLSD Docket 05/26/2009 Page 1 of 6 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRAi 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
JANE DOE NO. 3, CASE NO.: 08-CV-80232-
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA/ 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARRA 
Plaintiff, 
VS. 
JITERF.Y EPSTEIN, 
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Defendant. 
JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRAi 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
JANE DOE NO. 7, CASE NO.: 08-CV-80993-MARRA I 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
C.M.A., CASE NO.: 08-CV-80811-MARRA/JOHNSON 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
JANE DOE, CASE NO.: 08-CV-80893-MARRA. 
Plaintiff, 
vs. 
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Case 9:08-cv-80119-KAM Document 114-3 Entered on FLSD Docket 05/26/2009 Page 3 of 6 
JEFFREY EPSTEIN, 
Defendant. 
/ 
JANE DOE NO. II, CASE NO.: 08-CV-80469-MARRA 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
/ 
JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARRA 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
/ 
JANE DOE NO. 102, CASE NO.: 09-CV-80656-MARRA 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
ORDER 
THIS CAUSE comes before the Court on Plaintiffs Jane Doe No. 101 and Jane Doe No. 
102's Motion for an Order for the Preservation of Evidence and Incorporated Memorandum of 
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Case 9:08-cv-80119-KAM Document 114-3 Entered on FLSD Docket 05/26/2009 Page 4 of 6 
Law (DE #j, filed May 26, 2009. Plaintiffs represent that Defendant has not agreed to the 
relief requested in this motion. The Court has carefully considered the motion and is otherwise 
fully advised in the premises. 
It is ORDERED AND ADJUGED that Plaintiffs' Motion (DE # 3 is GRANTED. 
A. Defendant, Jeffrey Epstein, and his employees, his agents, his attorneys, and other 
nonparties are directed to take every reasonable step to preserve all evidence, 
including, but not limited to, evidence related to the October 25 search, documents, 
data, and tangible things, which includes, but is not limited to, writings; records; files; 
correspondence; digital or chemical process photographs (including negatives); 
reports; memoranda; calendars; diaries; minutes; electronic messages; voicemail; e-
mail; telephone message records or logs; computer and network activity logs; hard 
drives; backup data; removable computer storage media, such as tapes, disks, and 
cards; printouts; document image files; web pages; databases; spreadsheets; software; 
books; ledgers; journals; orders; invoices; bills; vouchers; checks; statements; 
worksheets; summaries; compilations; computations; charts; diagrams; graphic 
presentations; drawings; films; charts; video, phonographic, tape, or digital recordings 
or transcripts thereof; drafts; jottings; and notes. Information that serves to identify, 
locate, or link such material, such as file inventories, file folders, indices, and 
metadata, is also included. Specifically, Defendant must preserve the following 
evidence: records of phone communications; records of domestic and international 
travel, including travel in Defendant's private airplanes; former and current employee 
records; tax returns; medical bills; bills regarding any other expenses; all documents 
evidencing payment by Defendant of U.S. currency and/or merchandise to each 
victim; any evidence stored in Defendant's storage unit; photos of Defendant's 
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mansions; any diary, log, memo pad, calendar, or other writing reflecting date of each 
victim's visit(s) to Defendant's mansions; any diary or document wherein each victim 
wrote regarding a victim's visit to Defendant's mansions; all documents sent to or by 
the PBPD, the FBI, the USAO, or the PBSAO; and all computers used by Defendant 
and/or his agents and/or employees since 1998. 
13. The duty extends to documents, data, and tangible things in the possession, custody, 
and/or control of the parties to this action and any employees, agents, contractors, 
carriers, bailees, or other nonparties who possess materials reasonably anticipated to 
be subject to discovery in these actions. Counsel is under an obligation to exercise 
reasonable efforts to identify and notify such nonparties. 
C. "Preservation" is to be interpreted broadly to accomplish the goal of maintaining the 
integrity of all documents, data, and tangible things reasonably anticipated to be 
subject to discovery in these actions under Rules 26, 45, and 56(e) of the Federal 
Rules of Civil Procedure. Preservation includes taking reasonable steps to prevent 
the partial or full destruction, alteration, testing, deletion, shredding, incineration, 
wiping, relocation, migration, theft, or mutation of such material, as well as negligent 
or intentional handling that would make material incomplete or inaccessible. 
D. Defendant, Jeffrey Epstein, and his employees, agents, and attorneys shall preserve 
any evidence from the October 25, 2005 execution of a search warrant at his mansion 
at 358 El Brillo Way in Palm Beach, Florida, that has already been returned to him by 
the Palm Beach Police Department. 
E. If an objection or privilege is raised, the parties may raise the issue with this Court 
and shall preserve the evidence in question pending resolution by the Court. 
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F. The parties, without leave of Court, may agree in writing that certain documents or 
categories of evidence need not be preserved as otherwise required by this Order. If 
such agreement is reached, such agreement is effective upon signing and without 
further order of this Court. 
G. This Order shall not be deemed to create any "safe harbors" for the destruction of 
evidence. If this Court determines that evidence has been destroyed or lost, whether 
knowingly or not, it will impose appropriate sanctions. 
H. Each party shall bear its own costs for complying with this Order. 
DONE AND ORDERED in at West Palm Beach, Palm Beach County, Florida, 
this of 2009. 
KENNETH A. MARRA 
United States District Court Judge 
Copies to: 
All counsel of record 
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