EFTA00727603.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV- 80893 — MARRA/JOHNSON FILED by JUL 0 8 2010 JANE DOE, STEVEN M. LARILLORE ERIC U.S. Mt CT. . Of FLA. • W.P.B. Plaintiff, v. JEFFREY EPSTEIN, Defendants. Joint Stipulation Of Mootness and Withdrawal Of Plaintiffs Emergency Motion For Hearing Requesting That The Court Find Epstein In Civil Contempt Of The Court's Two Orders Forbidding Harassment And Indirect Contact, For Appropriate Sanctions, And Additional Remedies Including Referral For Criminal Contempt Plaintiff, JANE DOE and Defendant, JEFFREY EPSTEIN ("Epstein"), hereby file their Joint Stipulation of Mootness and Withdrawal Of Plaintiffs Emergency Motion for Hearing Finding That Epstein Is In Civil Contempt of the Court's Two Orders Forbidding Harassment And Indirect Contact, For Appropriate Sanctions, And Additional Remedies Including Referral for Criminal Contempt (Des 194 and 195)(the "Motion for Contempt"), and each state: 1. On July 2, 2010, Plaintiff filed the Motion for Contempt and an associated Motion to file same under seal. (DEs 194 and 195) 2. The parties have resolved the above lawsuit. 3. Plaintiff's counsel has been advised that the investigator was hired by Defense Counsel and was supervised by Defense Counsel. 4. Putting aside certain fact disputes between the Plaintiff, Defendant and their respective investigators as to what occurred, Plaintiff's counsel agrees to withdraw the Motion as 1 EFTA00727603 it is now moot. WHEREFORE, Plaintiff and Defendant requests that the Court enter and order finding the above Motion for Contempt as moot and withdrawn, and grant any additional relief the Court deems just and proper. Local Rule 7.1 Statement Pursuant to the above rule, the undersigned counsel and Plaintiff's counsel have conferred and have agreed to same. Respectfully submitted, By: /s/ Robert I. itt.n Jr. ROBERT a CRITTON, JR., Florida Bar No. 224162 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following service list in the manner specified via transmission of Notices of Electronic Filing generated by CM/ECF on this n day of July, 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss. P.A. & Lehrman. P Co-Counselfor Defendant Jeffrey Epstein Paul G. Cassell, Esq. Pro Hoc Vice 2 EFTA00727604 o-counse or Plaintiff (Co-Counselfor Defendant Jefrey Epstein) 3 EFTA00727605