Court Records
Case 9:08-cv-80119-KAM Document 224-1 Entered on FLSD Docket 07/29/2009 Page 1 of 7
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-
Plaintiff,
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Case 9:08-cv-80119-KAM Document 224-1 Entered on FLSD Docket 07/29/2009 Page 2 of 7
vs.
JEFFREY EPSTEIN,
Defendant.
JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRA
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
JANE DOE NO. 7, CASE NO.: 08-CV-80993-
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
C.M.A., CASE NO.: 08-CV-80811-MARRA
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
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JANE DOE, CASE NO.: 08-CV-80893-
Plaintiff,
vs.
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,
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Case 9:08-cv-80119-KAM Document 224-1 Entered on FLSD Docket 07/29/2009 Page 4 of 7
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
Law (DE #114), filed May 26, 2009. and the Court's Order ( DE #192), filed July 6, 2009. The
parties having agreed and the Court having carefully considered the motion and being otherwise
fully advised in the premises.
It is ORDERED AND ADJUDGED that Plaintiffs' Motion (DE # 114) is GRANTED as
follows:
A. Defendant, Jeffrey Epstein, and his employees, his agents, and his attorneys are
directed to take every reasonable step to preserve all evidence, to the extent it exists,
including, but not limited to, evidence related to the October 25, 2005 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;
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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 related in any
way to these Plaintiffs; all documents evidencing payment by Defendant of U.S.
currency and/or merchandise to each person on the list of victims provided by the
United States Attorney's Office ("USAO list"); any evidence stored in Defendant's
storage unit; all photographs of the interior and exterior of Defendant's Palm Beach
mansion as it appeared in 1998 through October 2005; any diary, log, memo pad,
calendar, or other writing reflecting the date that each person on the USAO list visited
Defendant's mansion; any diary or document wherein each victim on the USAO list
wrote regarding any visit(s) to Defendant's mansions; all documents sent to or by the
Palm Beach Police Department ("PBPD"), the FBI, the USAO, or the Palm Beach
State Attorney's Office ("PBSAO")to or by the Defendant; and all computers used by
Defendant and/or his agents and/or employees during 1998 through and including
October 25, 2005, the date of the search warrant.
B. The duty extends to documents, data, and tangible things in the possession, custody,
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and/or control of the parties to this action and any employees, agents, or attorneys
who possess materials reasonably anticipated to be subject to discovery in these
actions. Counsel shall be directly responsible only to the extent they arc in possession
or control of evidence. Counsel shall provide a copy of this Order to Defendant and
those employees or agents whom defense counsel knows, or has reason to know, may
have evidence.
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 been, or will be, returned to him
by the PBPD.
E. If an objection or privilege is raised, the parties may raise the issue with this Court in
a timely fashion and shall preserve the evidence in question pending resolution by the
Court.
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
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such agreement is reached, such agreement is effective upon signing and without
further order of this Court.
G. If this Court determines that evidence has been destroyed or lost, it may impose
appropriate sanctions based upon motion and an evidentiary hearing, if necessary.
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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