Court Records
Case 9:08-cv-80119-KAM Document 232 Entered on FLSD Docket 07/30/2009 Page 1 of 7
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/=M
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
/
JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA'
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
/
JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA I
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
JANE DOE NO. 5, CASE NO.: 08-CV-8038I-MARRA
Plaintiff,
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Case 9:08-cv-80119-KAM Document 232 Entered on FLSD Docket 07/30/2009 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-MARRA
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
C.M.A., CASE NO.: 08-CV-8081 I -MARRA
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
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JANE DOE, CASE NO.: 08-CV-80893-MARRA
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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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), entered July 6, 2009. The
parties are in agreement as to a substantial part of the language in their proposed orders, and the
Court has carefully considered the motion, the proposed orders, and is 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 relevant to these cases
that have been filed in federal court or that may lead to the discovery of admissible
evidence relevant to these cases, which includes evidence related to the October 25,
2005 search, documents, data, and tangible things, including 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;
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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 to preserve evidence extends to documents, data, and tangible things in the
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possession, custody, 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 are 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.
D. 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. An agreement to preserve evidence and this Order is not a waiver of any right
to object to production.
E. 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.
F. If this Court determines that evidence has been destroyed or lost in violation of this
Order, it may impose appropriate sanctions based upon motion and an evidentiary
hearing, if necessary.
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G. 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 30th of July, 2009.
/e ser - 2-
KENNETH A. MARRA
United States District Court Judge
Copies to:
All counsel of record
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