MEMY-1805 marker2 court-doe-v-epstein-80119 (salt 4090): 2434/2434

marker2/court-doe-v-epstein-80119/EFTA02748617/EFTA02748617.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CIV-80119-MARRA/JOHNSON
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related cases:
+
+08-80232, 08-08380, 08-80381, 08-80994,
+
+08-80993, 08-80811, 08-80893, 09-80469,
+
+09-80591, 09-80656, 09-80802, 09-81092
+
+## EPSTEIN'S REPLY TO JANE DOE #3'S RESPONSE TO EPSTEIN'S MOTION FOR SANCTIONS
+
+Defendant, JEFFREY EPSTEIN ("Epstein"), submits this Reply to Plaintiff's, Jane Doe #3, Response to Epstein's Motion for Sanctions and states:
+
+- 1. On January 13, 2010, Epstein filed a Motion for Sanctions (DE #450) against Jane Doe #3 for unilaterally terminating her Rule 35 IME on November 24, 2009.
+- 2. On February 1, 2010, Jane Doe #3 filed her Memorandum in Response to Defendant's Motion for Sanctions ("Response") (DE #456).
+- 3. Jane Doe #3's Response is based, in part, on the demonstrably false assertion that her counsel did not know Epstein kept an office in the building where the IME took place.
+- 4. As set forth in Epstein's Motion and in Jane Doe #3's Response (Exhibit A), Epstein's maintained an office on the le floor of the building located at 250 Australian Avenue, in West Palm Beach, Florida. Indeed, the Court's October 23, 2009 Order (DE #369) clearly
+
+Jane Doe #2 V. ElAtelQ
+
+Case No. 08-CIV-80119
+
+Epstein's Reply to Jane Doe #3's Response to Epstein's Motion for Sanctions
+
+Page 2 of 6
+
+provides that Epstein will view the depositions from his office, "in a separate room on the 14th floor...."
+
+5. Jane Doe #3's assertions that the Florida Science Foundation is not listed on the building's directory or that the company was administratively dissolved in September, 2009 for failure to file an annual report do not controvert the fact that Jane Doe #3's counsel knew Epstein maintained an office at 250 Australian Avenue.
+
+6. On November 10, 2009, two weeks before Jane Doe #3's IME, Adam Horowitz attended the deposition of at 250 Australian Avenue in which Epstein viewed the deposition from his office on the 14i ' floor. Thus, any argument that counsel did not know Epstein still maintained an office at 250 Australian Avenue, either because the Florida Science Foundation's name was not on the building directory or because the company was administratively dissolved in September 2009 should fall on deaf ears. It is clear that Mr. Horowitz knew, two weeks before Jane Doe #3's IME, that Epstein's office was located at 250 Australian Avenue.'
+
+7. Just as the Florida Science Foundation is not listed on the building's directory, neither is Jessica Arbour, counsel who attended the subject IME, listed as an attorney on the Mermelstein & Horowitz, P.A. (M&H) website. Attached as Exhibit A is the "Attorneys" section of the M&H website, which noticeably fails to list Ms. Arbour. In addition, Ms. Arbour's page on Martindale.com (attached as Exhibit B) does not indicate any affiliation with
+
+In addition, counsel for Jane Doe #3 attended the following depositions at 250 Australian Ave., which Epstein viewed from a video feed to his: LM on September 24, 2009, Jane Doe on September 30, 2009, Jane Doe #4 on October 27, 2009, as well as others. There is no question Jane Doe #3's counsel knew Epstein maintained an office in the building.
+
+lane Doe #2 v. Epstein
+
+Case No. 08-CI V.80119
+
+Epstein's Reply to lane Doe #3's Response to Epstein's Motion for Sanctions
+
+Page 3 of 6
+
+M&H. It merely provides a Miami address (different from M&H's office address) and states that she attended DePaul law school and was admitted to practice in 2009.
+
+8. Although it is uncertain exactly when Ms. Arbour joined M&H, the Florida Bar News announced that she joined the firm in its October 15, 2009 edition of "On the Move" (attached as Exhibit C), which was just over one month before the subject IME. Thus, it is likely that Ms. Arbour joined M&H sometime in late 2009.
+
+9. If Ms. Arbour did not know Epstein maintained an office at the building, it is only because M&H failed to advise her of this fact.
+
+10. That III MI not have known that Epstein maintained an office at 250 Australian Avenue is inapposite since knowledge by any member of a law firm is imputed to all attorneys in the firm. See e.g. In re Mortgage & Realty Trust, 195 B.R. 740, 754-55 (Bankr., C.D. Cal. 1996) (noting that the imputed knowledge theory holds that knowledge by any member of a law firm is knowledge by all of the attorneys in the firm, partners as well as associates); Westinghouse Elec. Corp. v. Kerr Corp., 50 F.2d 1311, 1318 (7th Cir. 1978) (holding that rule regarding imputation of knowledge applies equally to large firms as well as smaller firms).
+
+11. Thus, since Adam Horowitz knew that Epstein maintained an office in the building two weeks before the subject IME, this knowledge is imputed to Ms. Arbour and she is deemed to have knowledge of this fact.
+
+12. Moreover, the purpose behind the Court's October 23, 2009 Order (DE #369) was to provide a procedure to avoid Epstein crossing paths with the respective Plaintiffs at their
+
+)ane Doe 42 v. Epstein
+
+Case No. 08-CIV-80119
+
+Epstein's Reply to Jane Doe 43's Response to Epstein's Motion for Sanctions
+
+Page 4 of 6
+
+depositions since Epstein maintained an office at the building where the depositions were to take place.
+
+13. M&H's failure to inform their associate, Ms. Arbour, that Epstein maintained an office in the building was likely the cause of the instant dispute. Had Ms. Arbour been told of this important fact, she likely would have made some arrangement or taken some precaution to avoid her client seeing Epstein. For example, Ms. Arbour could have called the undersigned the day before the IME and stated "I am attending the IME of my client tomorrow, is Epstein going to be at his office? If so, we should consult with each other about when our respective clients will be coming and going from the building to avoid a run-in." Or, once Ms. Arbour realized that her client would be going outside to take smoke breaks, she could have called the undersigned and said "my client is going to be outside taking smoke breaks from time to time throughout the day. Should we designate an area for the smoke breaks that Epstein will not walk by? Should we call you when we're going outside?" Ms. Arbour could have also followed the procedure outlined in DE #369 (assuming she knew of such procedure). There are a myriad of different things Ms. Arbour could have done, and may very well have done, had she been informed by M&H that Epstein maintained an office in the building.
+
+14. Because this alleged encounter, which Epstein denies because he did not see Jane Doe #3 or her counsel Epstein's Affidavit, Exhibit A to DEN 450), was wholly the fault of Jane Doe #3's counsel, the Court should grant Epstein's Motion for Sanctions.
+
+15. Jane Doe #3's unilateral cancellation of the IME was not justified and resulted in a substantial waste of physician time, attorney time, court reporter and videographer time. The costs associated with the court reporter and videographer currently totals \$1,260.00 for Visual Awe Doe #2 v. Eostein
+
+Case No. 08-CIV-S0119
+
+Epstein's Reply to Jane Doe #3's Response to Epstein's Motion for Sanctions
+
+Page 5 of 6
+
+Evidence and \$2,207.65 for Prose Court Reporting for a total amount of \$3,467.65. See Exhibit B to DE #450.
+
+16. Now, Dr. will be required to travel back to West Palm Beach to complete Jane Doe #3's IME. Moreover, additional court reporter and videographer expenses will be incurred to complete the IME.
+
+17. Because of her unjustified cancellation of the IME, Jane Doe #3 should bear the foregoing costs.
+
+WHEREFORE, Defendant moves for an order granting sanctions against Jane Doe #3, to include attorneys fees and costs as set forth above and costs associated with the attendance of the court reporter, the transcript and the presence of the videographer and direction that Jane Doe #3 appear for !ME within fifteen (15) days from the date of the Court's order at the undersigned's office, and for such other and further relief as this court deems just and proper.
+
+/s/ Michael J. Pike
+
+Robert D. Critton Jr.
+
+Florida Bar #224162
+
+Michael J. Pike
+
+Florida Bar #617296
+
+Attorneys for Defendant Epstein
+
+## 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 by CM/ECF on this 1 day of February, 2010:
+
+Jane Doe #2 v. Epstein
+
+Case No. 08-CIV-80119
+
+Epstein's Reply to Jane Doe #3's Response to Epstein's Motion for Sanctions
+
+Page 6 of 6
+
+Stuart S. Mermelstein, Esq.
+
+Adam D. Horowitz, Esq.
+
+Mermelstein & Horowitz, P.A.
+
+18205 Biscayne Boulevard
+
+Suite 2218
+
+Miami, FL 33160
+
+305-931-2200
+
+Fax: 305-931-0877
+
+[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com)
+
+[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com)
+
+*Counsel for Plaintiff Jane Doe #3*
+
+Jack Alan Goldberger
+
+Atterbury Goldberger & Weiss, P.A.
+
+250 Australian Avenue South
+
+Suite 1400
+
+West Palm Beach, FL 33401-5012
+
+561-659-8300
+
+Fax: 561-835-8691
+
+[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net)
+
+*Co-Counsel for Defendant Jeffrey Epstein*
+
+Respectfully submitted,
+
+By: /s/ Michael J. Pike
+
+ROBERT D. CRITTON, JR., ESQ.
+
+Florida Bar No. 224162
+
+[rcrit@bclclaw.com](mailto:rcrit@bclclaw.com)
+
+MICHAEL J. PIKE, ESQ.
+
+Florida Bar #617296
+
+[mpike@bclclaw.com](mailto:mpike@bclclaw.com)
+
+BURMAN, CRITTON, LUTTIER & COLEMAN
+
+515 N. Flagler Drive, Suite 400
+
+West Palm Beach, FL 33401
+
+561/842-2820 Phone
+
+561/515-3148 Fax
+
+*(Counsel for Defendant Jeffrey Epstein)*

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marker2/court-doe-v-epstein-80119/EFTA02748623/EFTA02748623.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CIV-801 I 9-MARRA ✓
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+Related cases:
+
+08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+/
+
+## ORDER
+
+THIS CAUSE is before the Court upon Defendant Jeffrey Epstein's "Motion for an Extension Directed to the Court Pursuant to Rule 4, Review and Appeal - Southern District, In Connection with this Court's Order Dated February 4, 2010 (DE 462)." See DE 464. In his Motion, Defendant seeks additional time to file an appeal of Magistrate Judge February 4, 2010 Order compelling production of certain documents within 14 days from the date of that Order. Upon consideration of the motion, response (DE 465), and reply (DE 466), it is hereby
+
+ORDERED AND ADJUDGED that Defendant's Motion for an Extension (DE 462) is GRANTED IN PART AND DENIED IN PART as follows:
+
+(I) The deadline for Defendant to file an appeal of Magistrate Judge February 4, 2010 Order is extended to Friday, February 26, 2010.
+
+(2) In the event that Magistrate Judge February 4, 2010 Order is affirmed on
+
+appeal, Defendant will have three (3) business days from the date of this Court's order to produce the documents at issue.
+
+DONE AND ORDERED in at West Palm Beach, Palm Beach County,
+
+Florida, this 11ih day of February, 2010.
+
+KENNETH A. MARRA United States District Judge
+
+Copies to: all counsel of record

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marker2/court-doe-v-epstein-80119/EFTA02748625/EFTA02748625.md

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+AO BSA (Rev. 01/09) subpoena to Tally at • Deposition or to Pinta Deoatents in a CiA Action
+
+# UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of Florida
+
+Jane Doe No. 2 Plaine V. Jeffrey Epstein Defeeloar Civil Action No. 08-CV-80119-MARRNJOHNSO (If the action is pending in another district, state when:
+
+To: Alfredo Rodriguez 11349 SW 86 Lane, Miami, FL
+
+#### SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A
+
+S;24101
+
+Ito Testimony: YOU ARE COMMANDED to appear at the time, te, and set fo belo to testify at <sup>a</sup> deposition to be taken in this civil action. If you are an organization that is not aparty in this case, you must designs one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment:
+
+| Place: Kress Court Reporting<br>1031 Ives Dairy Road, Suite 228, Bldg. 4<br>North Miami, FL 33179 | Date and Time:<br>07/29/2009 11:00 am |
+|---------------------------------------------------------------------------------------------------|---------------------------------------|
+|---------------------------------------------------------------------------------------------------|---------------------------------------|
+
+The deposition will be recorded by this method: Court Reoorter and Videographer
+
+Ql Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material:
+
+Any and all journals, notes, diaries, writings or other documents referring or relating to Jeffrey Epstein or events or Incidents occurring at his residence located at 358 El Brillo Way, Palm Beach, Florida, including without limitation, the journal you described to Palm Beach Police that contains names of girls who visited the residence.
+
+The provisions of Fed. R. Civ. P. 45(c), relating to your protection as <sup>a</sup>person subject to asubpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached.
+
+Date: 07/24/2009 CLERK OF COURT
+
+&pones of Clerk or Deputy Oen
+
+OR
+
+The name, address, e-mail, and telephone number of the attorney representing (name loony) Jane Doe No. <sup>2</sup> , who issues or requests this subpoena, are:
+
+Mermeistein & Horowitz, P.A. - Adam D. Horowitz, Esq.
+
+18205 Biscayne Blvd., Suite 2218, Miaml, FL 33160
+
+Tel: 305-931-2200 - email: ahorowitz@sexabuseattomey.com
+
+![](_page_0_Picture_26.jpeg)
+
+AO RSA (Rev. 01/09) Subpooto to Testify at aDeposition or to Produce Documents in a Civil Action (Page 2)
+
+Civil Action No. 08-CV430119-MARMOHNSO
+
+#### PROOF OF SERVICE
+
+(This section should not be filed with the court unless required by Fee R Q'. P. 45.)
+
+This subpoena for (name of individual and title, if any) was received by me on (dare)
+
+<sup>O</sup>I personally served the subpoena on the individual at (place) on (date) ; or <sup>O</sup>Heft the subpoena at the individual's residence or usual place of abode with (name) , <sup>a</sup>person of suitable age and discretion who resides there, On (date) , and mailed acopy to the individual's last known address; or Cl I served the subpoena on (name of Individual) designated by law to accept service of process on behalf of (name of organisation) <sup>O</sup>1 returned the subpoena unexecuted because Other 4,49: , who is on (date) ; or ; or
+
+Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
+
+My fees are S for travel and S for services, for a total of S 0.00
+
+Date: Server's signature Printed name and title Server's address
+
+<sup>I</sup>declare under penalty of perjury that this information is true.
+
+Additional information regarding attempted service, etc:
+
+# MERMELSTEIN & HOROWITZ PA
+
+ATTORNEYS AT LAW
+
+July 24, 2009
+
+### Via Process Server
+
+Alfredo Rodriguez 11349 SW 86th Lane Miami, FL 33173
+
+Re: Jane Does v. Jeffrey Epstein
+
+Dear Mr. Rodriguez:
+
+Stuart S. MermNsteln Tel 305.931.2200 Fax 305.931.0877 sem esevabuseattomey.com
+
+18205 Biscayne Blvd. Suite 2218 Mami, Florida 33160 www.sexabuseattorney.com
+
+As you are aware, your deposition has been rescheduled to July 29, 2009 at 11:00 a.m. due to your car problems on the previously scheduled date of July 23, 2009. We will provide car service to transport you to and from the deposition. The car will pick you up at 9:45 a.m. on Wednesday, July 29, 2009. Please review the witness and document subpoena you are being provided by the process server.
+
+Thank you for your attention to this matter.
+
+Very truly yours,
+
+Stuart S. Mermelstein
+
+SSM/Ir
+
+## UNITED STATES DISTRICT COURT MIAMI-DADE District of Florida
+
+Case Number: 08-CV-80119-MARRA/JOHNSO
+
+Plaintiff:
+
+JANE DOE NO. 2
+
+vs.
+
+Defendant:
+
+JEFFREY EPSTEIN
+
+For.
+
+Adam D Horowitz
+
+MERMELSTEIN & HOROWITZ P.A.
+
+18205 Biscayne Bolevard
+
+Suite 2218
+
+Miami, FL 33160
+
+Received by MIAMI-DADE PROCESS, INC. on the 24th day of July, 2009 at 4:00 pm to be served on ALFREDO RODRIGUEZ, 11349 SW 86 LANE, MIAMI, FL.
+
+I, RAFAEL (BUDA) NMI do hereby affirm that on the 25th day of July, 2009 at 5:24 pm, I:
+
+Individually Served the within named person with a true copy of this SUBPEONA TO TESTIFY AT DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION with the date and hour endorsed thereon by me, pursuant to State Statutes.
+
+<sup>I</sup>certify that I am over the age of 18, have no interest in the above action, and am a Process Server, in good standing, in the judicial circuit in which the process was served and have proper authority in the jurisdiction in which this service was made..Under penalties of perjury, I declare that I have read the foregoing document and that the facts stated in it are true F.S. 92.525 Verification of documents.
+
+FAEL (BUDA) rtified Process erver
+
+MIAMI-DADE PROCESS, INC. 247 S.W. 8 Street # 293 Miami, FL 33130-3513 (786) 486-2832
+
+Our Job Serial Number 2009001154

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marker2/court-doe-v-epstein-80119/EFTA02748629/EFTA02748629.md

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+CASE NO: 08-CV-80994  
+Plaintiff,  
+Vs.  
+JEFFREY EPSTEIN,  
+Defendant.
+
+CASE NO: 08-CV-80993  
+Plaintiff,  
+Vs.  
+JEFFREY EPSTEIN,  
+Defendant.
+
+C.M.A., CASE NO: 08-CV-80811  
+Plaintiff,  
+Vs.  
+JEFFREY EPSTEIN,  
+Defendant.
+
+CASE NO: 08-CV-80893  
+Plaintiff,  
+Vs.  
+JEFFREY EPSTEIN,  
+Defendant.
+
+1 IN THE CIRCUIT COURT OF THE 15TH  
+2 JUDICIAL CIRCUIT IN AND FOR  
+3 PALM BEACH COUNTY, FLORIDA  
+4 CASE NO. 502008CA037319XXXXMB AB
+
+5 B.B.,  
+6 Plaintiff,  
+7 Vs.  
+8 JEFFREY EPSTEIN.  
+9 Defendant.
+
+10  
+11  
+12 1031 Ives Dairy Road  
+13 Suite 228  
+14 North Miami, Florida  
+15 August 7, 2009  
+16 1:15 p.m. to 5:30 p.m.  
+17 CONTINUED  
+18 VIDEOTAPED  
+19 DEPOSITION  
+20 of  
+21 ALFREDO RODRIGUEZ  
+22 taken on behalf of the Plaintiffs pursuant  
+23 to a Re-Notice of Taking Continued Videotaped  
+24 Deposition (Duces Tecum)  
+25 - - -
+
+CASE NO: 08-CV-80469  
+Plaintiff,  
+Vs.  
+JEFFREY EPSTEIN,  
+Defendant.
+
+CASE NO: 08-CV-80591  
+Plaintiff,  
+Vs.  
+JEFFREY EPSTEIN,  
+Defendant.
+
+CASE NO: 08-CV-80656  
+Plaintiff,  
+Vs.  
+JEFFREY EPSTEIN,  
+Defendant.
+
+1 APPEARANCES:  
+2  
+3 MERMELSTEIN & HOROWITZ, P.A.  
+4 BY: ADAM HOROWITZ, ESQ.  
+5 18205 Biscayne Boulevard  
+6 Miami, Florida 33160  
+7 Attorney for Jane Doe 2, 3, 4, 5,  
+8 6, and 7.  
+9 ROTHSTEIN, ROSENFELDT ADLER  
+10 BY: BRAD 1 [REDACTED], ESQ., and  
+11 CARA [REDACTED], ESQ.  
+12 Las Olas City Centre  
+13 Suite 1650  
+14 401 East Las Olas Boulevard  
+15 Fort Lauderdale, Florida 33301  
+16 Attorney for Jane Doe and E.W.  
+17 And L.M.  
+18  
+19 PODHURST ORSECK  
+20 BY: KATHERINE W. EZELL, ESQ.  
+21 25 West Flagler Street  
+22 Suite 800  
+23 Miami, Florida 33130  
+24 Attorney for Jane Doe 101 and 102.  
+25  
+26 LEOPOLD-KUVIN  
+27 BY: ADAM J. LANGINO, ESQ.  
+28 2925 PGA Boulevard  
+29 Suite 200  
+30 Palm Beach Gardens, Florida 33410  
+31 Attorney for B.B.
+
+[REDACTED] bedroom?
+
+A. Yes, [REDACTED].
+
+Q. And how would you do that? If you want to turn the page over for the upstairs you could do that.
+
+A. Okay.
+
+MR. CRITTON: Are you going to mark this as an exhibit?
+
+MS. EZELL: Uh-huh.
+
+MR. CRITTON: Would that be Exhibit 3?
+
+MR. [REDACTED]: I think so.
+
+(Exhibit No. 3 was marked for Identification.)
+
+THE WITNESS: This is the [REDACTED] bedroom, [REDACTED] bath, and there were one, two -- the rest of the bedrooms were here and the [REDACTED] bedroom was here. This is [REDACTED] bath one and [REDACTED] bath two.
+
+So the staircase came to the second floor like this and it was between the first and second bedroom. And you could go through here and you enter a foyer with double doors here, double doors here, and you enter the [REDACTED] bath.
+
+[REDACTED] EZELL:
+
+Q. All right. How would you get to the [REDACTED] bathroom on that end?
+
+A. You go through these double doors, go around the bed and you gain access to the [REDACTED] bedroom -- [REDACTED] bathroom, sorry.
+
+Q. And then there was another [REDACTED] bathroom on the other side of the room?
+
+A. Yes, [REDACTED].
+
+Q. Where generally did the massages take place?
+
+A. Right here, [REDACTED].
+
+Q. And is that in the [REDACTED] bathroom?
+
+A. [REDACTED] bathroom, yes.
+
+Q. Do you recall what color the tile was in that bathroom?
+
+A. There was carpet.
+
+Q. Was there tile on the walls or marble or --
+
+A. There was a sauna here with marble but outside the sauna everything was carpet, and the walls, they didn't have any tile. [REDACTED] yes, I will say four feet off the floor they will have marble.
+
+Q. And do you remember what color marble it was?
+
+A. [REDACTED].
+
+1 pool at the house?
+
+2 A. Yes, [REDACTED].
+
+3 Q. And were these sometimes the same girls that came to give massages?
+
+4 A. Yes, [REDACTED].
+
+5 Q. Were there girls in addition to those who came to give massages who hung around the pool?
+
+6 A. The girls who were staying at the house.
+
+7 Q. Okay. And so they weren't girls who just regularly came to hangout around the pool?
+
+8 A. No, [REDACTED].
+
+9 [REDACTED] EZELL: Excuse me. Can we go off the record for a minute?
+
+10 (Thereupon, a recess was had.)
+
+11 THE VIDEOGRAPHER: We're back on the record with tape number two.
+
+12 BY MS. EZELL:
+
+13 Q. Mr. Rodriguez, did you receive a subpoena that asked you to bring documents with you to the deposition?
+
+14 A. Yes, [REDACTED].
+
+15 Q. And did you bring any with you?
+
+16 A. I couldn't find anything at my house.
+
+17 Q. Okay. I believe we talked about a journal that you kept, and you looked for that?
+
+Page 319 A. Yes, Q. And you couldn't find it? A. I give it to Detective Joe. Q. Recall. A. Yes, Q. You mentioned that you called Mr. can-Luc Bernell about a recommendation when you re lookin b. A. Yes, Q. And did you know him from his visits in e home? A. Yes, Q. Did you say that his wife's name was Eva? MR. CRITTON: Form. THE WITNESS: No, al EZELL: Q. Do you know what his wife's name was? A. Eva was amodel, a former model from years past who was friend of Mr. Epstein. Do you know if she was married to Glenn Do you know Mr. la MR. CRITTON: Form. THE WITNESS: I believe, yeah, I'm not ure, EZELL:
+
+1 Page 321 1 BY MS. EZELL: <sup>2</sup>Q. Did they ever visit Mr. Epstein at the 3 home when ere there? 4 A. Yes, <sup>5</sup>Q. How old was the little girl at that time? 6 A. Eight years old. <sup>7</sup>Q. Did the girl's father come to visit as 8 well? <sup>10</sup>Q. And \*remember his name? 9 A. Yes, 11 A. No, <sup>12</sup>Q. Do you remember hearing anything about 13 what he does for aliving? 14 A. No, <sup>15</sup>Q. Can,describe him? <sup>16</sup>A. Tall, American born, I will say 50 years 17 old. <sup>18</sup>Q. What color hair did he have? 19 A. At that time it was black with a few 20 -hairs. <sup>21</sup>Q. Were there drawings of nude women in the 22 house? 23 A. No, <sup>24</sup>Q. Well paintings of nude women in the 25 house?
+
+Page 320 Q. Is she now adoctor? A. No, she was amodel, her husband could be a doctor but I don't think she is. Q. Okay. So is Jean-Luc Bernell married; to your knowledge? A. I don't know, lilt Q. I think I must have gotten confused because we were talking about the picture in the house of the little girl who is lifting up her skirt or her underpants, I'd forgotten what it was. A. Yes, MR. ON: Form. BY MS. EZELL: Q. And I thought you said that that was Jean-Luc's child. Q. Eva.? A. No, she is Mrs. Eva. Q. And !II leffrey Epstein's Goddaughter? A. Yes, A. Yes, Q. Do you now where she and her mother live? A. They live in Manhattan. MR. CRITTON: Form.
+
+1 A. Yes, Q. Did any ihose appear to be 3 Ms. Maxwell? <sup>4</sup>A. Yes, Q. You mentioned that Louella who was still 6 working there when you left -- A. Yes, lin Q. -- was a very religious woman -- 9 A. Yes, Q. -- all sometimes be upset about 11 seeing pictures of nude girls or having to pick up 12 sex toys, et cetera. MR. CRITTON: Form. THE WITNESS: Yes, BY MS. EZELL: Q. And you said that you remembered her 17 crying because there was apicture of the Pope 18 next to apicture of a naked girl. MR. CRITTON: Form. THE WITNESS: BY MS. EZELL: Q. Do you know who that naked girl was? 23 A. I don't remember, Q. I believe David Copplld's name came 25 up in the last deposition as someone who would Page 322

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marker2/court-doe-v-epstein-80119/EFTA02748632/EFTA02748632.md

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+**United States District Court**
+
+**SOUTHERN DISTRICT OF FLORIDA**
+
+FILED by \_\_\_\_\_ D.C.  
+**DEC - 1 2009**  
+STEVEN M. LARIMORE  
+CLERK U.S. DIST. CT.  
+S. D. OF FLA. - W.P.B.
+
+UNITED STATES OF AMERICA
+
+**CRIMINAL COMPLAINT**
+
+vs.
+
+ALFREDO RODRIGUEZ,
+
+CASE NUMBER: 09-8308-LRJ
+
+Defendant.  
+\_\_\_\_\_/
+
+I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my knowledge and belief.
+
+From at least as early as January 18, 2007, through on or about November 3, 2009, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendant,
+
+**ALFREDO RODRIGUEZ,**
+
+did corruptly conceal a record, document, or other object, with the intent to impair the object's availability for use in an official proceeding and otherwise corruptly obstructed or impeded an official proceeding, in violation of Title 18, United States Code, Section 1512(c).
+
+I further state that I am a Special Agent with the Federal Bureau of Investigation, and that this Complaint is based on the following facts:
+
+Please see attached Affidavit
+
+Continued on the attached and made a part hereof.
+
+*Christina J. Pryor*  
+Christina J. Pryor, Special Agent  
+Federal Bureau of Investigation
+
+Sworn to before me, and subscribed in my presence, upon my finding of probable cause.
+
+December / , 2009 at West Palm Beach, Florida  
+Date City and State
+
+LINNEA R. [REDACTED]  
+UNITED STATES MAGISTRATE JUDGE
+
+*Linnea R. [Signature]*  
+Signature of Judicial Officer
+
+**EXHIBIT**  
+C
+
+## AFFIDAVIT
+
+I, Christina J. Pryor, being duly sworn, do state and attest as follows:
+
+1. I am a Special Agent with the Federal Bureau of Investigation (FBI) and have been so employed for three (3) months. I am currently assigned to the Safe Streets Task Force, Miami Field Division, FBI Squad PB-2. Prior to joining the Miami Field Division, <sup>I</sup>attended the FBI Academy in Quantico, Virginia, for five (5) months where I received training in federal criminal laws and investigation techniques, including the laws related to obstruction of justice.
+
+2. This affidavit is based upon my own personal knowledge of the facts and circumstances surrounding the investigation, and information provided to me by other law enforcement officers. This affidavit does not purport to contain all the information known to me about this case but addresses only that information necessary to support a finding of probable cause for the issuance of acriminal complaint charging Alfredo Rodriguez with obstruction of official proceedings, in violation of Title 18, United States Code, Section 1512(c).
+
+3. On October 27, 2009, agents of the FBL met with and interviewed <sup>a</sup> cooperating witness ("CW"). The CW reported that, while conducting discovery in <sup>a</sup> pending civil case before the United States District Court for the Southern District of Florida, he came into contact with Alfredo Rodriguez ("Rodriguez"), who was asubpoenaed witness in the civil case.
+
+4. Rodriguez had been interviewed by FBI agents on January 18, 2007, in connection with a federal criminal investigation into the sexual exploitation of minors. Prior
+
+to being interviewed by FBI, Rodriguez had also been contacted and interviewed by local police detectives, and had been asked to produce documents related to the criminal investigation. The civil litigation involving the CW related to civil damages claims made by victims of the criminal activity that formed the basis of the state and federal criminal investigations.
+
+5. The CW explained to agents that Rodriguez had been deposed under oath on two occasions. The first deposition occurred on July 27, 2009, and the second deposition was conducted on August 9, 2009. In connection with those depositions, Rodriguez was served with a subpoena duces tecum that called for the production of several types of documentary evidence. The CW was present for both depositions and Rodriguez testified that he had no documents responsive to the subpoena duces tecum.
+
+6. In August 2009, after the conclusion of the second deposition, the CW received <sup>a</sup>phone call from Rodriguez. Rodriguez informed the CW that he had additional information that he had not previously disclosed to any law enforcement agency or any of the civil attorneys. Rodriguez described the information as, the Holy Grail or Golden Nugget and explained that he had compiled lists of additional victims in the case and their contact information. Rodriguez explained that the information contained hundreds of additional victims and their phone numbers from diverse geographic locations, including New York, New Mexico, and Paris, France.
+
+7. Rodriguez asked the CW to pay him \$50,000.00 and, in return, Rodriguez would turn over the documents relating to the victims. In his initial and subsequent
+
+communications with Rodriguez, the CW explained to Rodriguez that he was under subpoena to turn over such information and that it would be illegal for Rodriguez to demand money for turning over the information. Rodriguez persisted that he would only turn over the information in his possession in exchange for \$50,000.00.
+
+8. On October 28, 2009, in aconsensually-monitored phone call, the CW telephoned Rodriguez. Rodriguez again indicated that he would not turn over the information relating to the additional victims without monetary compensation. Rodriguez was told that an associate of the CW would be in touch with him regarding the information and exchange. The associate that the CW referred to was, in fact, an undercover employee (UCE) of the FBI.
+
+9. On October 29, 2009, the FBI UCE contacted Rodriguez via telephone. Rodriguez again explained that he would only turn over the information in exchange for monetary compensation. The UCE advised Rodriguez that it would take several days to acquire the funds and that once the funds were obtained, he/she would contact Rodriguez. During the conversation, Rodriguez admitted that he knew that the information was relevant to the FBI's criminal investigation and was called for by the investigation. Rodriguez explained that he had not turned over the information to the FBI because: (1) it was his "property" and he should be compensated for it; and (2) he was afraid that the target of the investigation would make him "disappear" or otherwise harm him, and the information was his "insurance policy."
+
+10. On November 2, 2009, the UCE made contact with Rodriguez via telephone.
+
+In that conversation, Rodriguez and the UCE continued the discussion regarding the purchase of the documents and scheduled ameeting for the following day.
+
+11. On November 3, 2009, Rodriguez met with the UCE at apredetermined location. During the meeting, Rodriguez produced a small bound book and several sheets of legal pad paper containing hand written notes. Rodriguez explained that he had taken the bound book from his former employer's residence while employed there in 2004 to 2005 and that the book had been created by persons working for his former employer. Rodriguez discussed in detail the information contained within the book, and identified important information to the UCE. In addition, Rodriguez admitted he had previously lied to FBI. Rodriguez asked the UCE about the \$50,000.00, took possession of the money, and began counting it.
+
+12. Rodriguez was then detained for Obstruction of Official Proceedings, Title 18, U.S. Code, Section 1512(c), and questioned. After Miranda warnings were administered by agents, Rodriguez waived his rights and signed a written waiver of those rights. Rodriguez admitted that he had the documents and book in his possession and had never turned them over to local law enforcement or the FBI. In addition, Rodriguez advised he had witnessed nude girls whom he believed were underage at the pool area of his former employer's home, knew that his former employer was engaging in sexual contact with underage girls, and had viewed pornographic images of underage girls on computers in his employer's home. Rodriguez was then released from custody for further investigation.
+
+13. The items that Rodriguez had attempted to sell to the UC for \$50,000.00
+
+were reviewed by an agent familiar with the underlying criminal investigation. As Rodriguez had described, the items contained information material to the underlying investigation that would have been extremely useful in investigating and prosecuting the case, including the names and contact information of material witnesses and additional victims. Had those items been produced in response to the inquiries of the state law enforcement officers or the FBI Special Agents, their contents would have been presented to the federal grand jury.
+
+Based upon the foregoing, your affiant believes that probable cause exists to believe that, from at least as early as January 18, 2007 through on or about November 3, 2009, in Palm Beach County, in the Southern District of Florida, and elsewhere, Alfredo Rodriguez did corruptly conceal arecord, document, or other object, with the intent to impair the object's availability for use in an official proceeding and otherwise corruptly obstructed or impeded an official proceeding, in violation of Title 18, United States Code, Section 1512(c).
+
+FURTHER YOUR AFFIANT SAYETH NAUGHT.
+
+A . PRY° C ENT FEDERAL BUREAU OF S ATION
+
+Sworn to and subscribed before me this / day of December, 2009.
+
+R. JOHNSO UNITED STA GISTRATE JUDGE
+
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 09-8308-LRJ
+
+UNITED STATES OF AMERICA
+
+vs.
+
+ALFREDO RODRIGUEZ,
+
+Defendant.
+
+## RIMINAL COVER SHEET
+
+- 1. Did this matter originate from a matter pending in the Northern Region of the United States Attorney's Office prior to October 14, 2003? Yes X No
+- 2. Did this matter originate from a matter pending in the Central Region of the United States Attorney's Office prior to September 1, 2007? Yes X No
+
+Respectfully submitted,
+
+JEFFREY H. SLOMAN ACTING UNITED STATES ATTORNEY
+
+By:
+
+A. VILLAFA Assistant United States Attorney Florida Bar No. 0018255 500 East Broward Boulevard, 7th Floor Ft Lauderdale, FL 33394 Telephone: 954-660-5946 Facsimile: 954-356-7230

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marker2/court-doe-v-epstein-80119/EFTA02748639/EFTA02748639.md

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CV-80119-MARRia
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+Related Cases:
+
+08-80232, 08-80380, 08-80381, 08-80994,
+
+08-80993, 08-80811, 08-80893, 09-80469,
+
+09-80591, 09-80656, 09-80802, 09-81092,
+
+/
+
+### PLAINTIFF JANE DOE NO. 2's MOTION TO COMPEL COMPLIANCE WITH SUBPOENA AND FOR ORDER OF CONTEMPT AGAINST ALFREDO RODRIGUEZ, AND INCORPORATED MEMORANDUM OF LAW
+
+Plaintiffs, Jane Doe No. 2, et al., by and through undersigned counsel, hereby file this Motion to Compel Compliance with Subpoena and for Order of Contempt Against Alfredo Rodriguez, and Incorporated Memorandum of Law, pursuant to Fed.R.Civ.P. 45(e), and state as follows:
+
+I. On July 25, 2009, Alfredo Rodriguez, a nonparty, was personally served a subpoena duces tecum to appear for deposition on July 29, 2009 ("the subpoena"). I The
+
+I Rodriguez was originally scheduled to appear for deposition on July 23, 2009, but failed to appear, claiming that he had "car troubles." Plaintiffs' counsel arranged for car service for him to appear at the July 29, 2009 deposition.
+
+subpoena and proof of service are attached as Exhibit "A." He was commanded to provide testimony and produce the following:
+
+> Any and all journals, notes, diaries, writings or other documents referring to or relating to Jeffrey Epstein or events or incidents occurring at his residence located at 358 El Brillo Way, Palm Beach, Florida, including without limitation, the journal you described to Palm Beach Police that contains the names of girls who visited the residence.
+
+2. Rodriguez did not object to the subpoena, nor did he claim the requested documents were privileged. He appeared for deposition on July 29, 2009, and August 7, 2009, but he failed to bring any of the requested documents. During his testimony on August 7, 2009, he swore that he had no responsive documents in his possession, and that he had turned over all such documents to the Palm Beach Police, including a journal which listed the names and phone numbers of young girls who came to the residence where he worked to give "massages" to Jeffrey Epstein. See Exhibit "B", deposition transcript of Alfredo Rodriguez, taken August 7, 2009, pp. 318-319.
+
+3. On February 1, 2010, Rodriguez was arraigned in federal court on obstruction of justice charges based on allegations that he intentionally withheld documents from federal and state law enforcement authorities. These withheld documents encompass those requested in Plaintiffs' subpoena, including the journal listing names and phone numbers of young girls. According to the criminal complaint, after making misrepresentations to federal law enforcement authorities and withholding documents, he attempted to sell these documents to a cooperating witness for \$50,000. Rodriguez made this offer after his deposition on August 7, 2009, at which he testified under oath that he did not possess the documents. A copy of the criminal complaint is attached hereto as Exhibit "C".
+
+4. It is likely that Rodriguez remains in possession of at least a copy of the journal that is the subject of the subpoena. Nonetheless, even if he did not retain a copy of the documents he handed to the cooperating witness, Rodriguez has the right to possession of those documents. Specifically, they are subject to production to Rodriguez in the discovery phase of his criminal case. The Assistant U.S. Attorney has an affirmative duty to produce all evidence in her possession that is material to the guilt of Alfredo Rodriguez, regardless of whether that information was requested by the Defendant or not. ee United States v. Bagley, 473 U.S. 667 (1985). 5!e also Fed.R.Crim P. 16(a)(1XE). Evidence is material that creates a reasonable probability that the outcome of a criminal proceeding would be different if suppressed. Id. at 682. The journal in question is the central piece of evidence in the prosecution's case against Alfredo Rodriguez. Accordingly, Alfredo Rodriguez has, at the very least, a right to possession of the documents that are the subject of the Plaintiff's subpoena.
+
+5. Rule 45(a)(1)(i), Fed.R.Civ.P., permits a party to subpoena documents from a nonparty that are within "that person's possession, custody or control." The term "control" under the federal discovery rules includes not only documents in the nonparty's possession, but also "the legal right to obtain the documents requested on demand." Searock v. Stripling, 736 F.2d 650 (11th Cir. 1984). Rodriguez has this right to obtain the subpoenaed documents under Bagley or in the normal course of discovery in his criminal case. <sup>2</sup> Therefore, it would not be an excuse or response that Rodriguez does not at this moment have possession of the subpoenaed documents.
+
+<sup>2</sup>These documents, moreover, are not subject to the Fifth Amendment "act of production" privilege since they are already in the possession of the government and their
+
+6. Plaintiffs' counsel has no other means of obtaining a copy of the documents in Rodriguez's possession except by means of an Order requiring full compliance with the July 25, 2009 subpoena.
+
+7. Plaintiff further seeks an Order pursuant to Fed.R.Civ.P. 45(e) to hold Rodriguez in contempt of court, together with sanctions as this Court deems appropriate.
+
+8. A Commentary to Rule 45(e) notes "the special role that contempt plays in enforcing subpoenas against nonparty witnesses". Fed.R.Civ.P. 45(e) (Commentary C45- 26, Contempt). Where a nonparty fails to comply with a subpoena, "the threat of contempt is the only remedy." Id. The civil contempt power of the Court extends to jail of the nonparty to enforce compliance:
+
+> The contempt most often associated with the disobedience of a subpoena is the category of "civil" contempt, the purpose of which is to enforce compliance in the particular case, with any penalty imposed designed to further the rights of the party in whose behalf the subpoena issued. When it is still within a person's power to comply, for example, and the person willfully refuses to, the person can be jailed until compliance is offered. Even the jailing in that case is an aspect of civil, not criminal, contempt.
+
+Id.
+
+9. Plaintiffs' counsel has conferred with federal public defender David Brannon, who stated that Alfredo Rodriguez objects to the relief requested in this Motion in that Alfredo Rodriguez claims to no longer be in possession of responsive documents.
+
+WHEREFORE, Plaintiffs, Jane Doe No. 2 et al., respectfully request (1) an Order requiring Alfredo Rodriguez to comply with the lawfully issued subpoena duces tecum and produce copies of all documents in his care, custody or control relating to Jeffrey Epstein,
+
+production would not "implicitly authenticate" them. See Fisher v. United States 425 U.S. 391, 410 (1976).
+
+including without limitation, the log of names and phone numbers he recently attempted to sell to a cooperating witness; (2) an order holding Alfredo Rodriguez in contempt of court for failure to comply with the lawfully issued subpoena, and providing that Alfredo Rodriguez shall produce the requested documents to Plaintiffs' counsel by a date certain or be arrested and jailed for civil contempt until such time as the documents are produced; and (3) any and all other relief this Court deems appropriate.
+
+# Certificate Pursuant to S.D.Fla.L.R. 7.1(A)(3)
+
+Counsel for the movant has conferred with counsel for the nonparty affected by the relief sought in this Motion in a good faith effort to resolve the issues raised in the Motion and has been unable to do so.
+
+Dated: February 17, 2010 Respectfully submitted,
+
+By: Is/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) ssm@sexabuseattorney.com Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattorney.com Jessica D. Arbour (FL Bar No. 67885) jarbour@sexabuseattomey.com MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: (305) 931-2200 Fax: (305) 931-0877
+
+#### CERTIFICATE OF SERVICE
+
+I hereby certify that on February 17, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+/s/ Adam D. Horowitz
+
+## SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida
+
+Jack Alan Goldberger, Esq. igoldberger@agwpa.com
+
+Robert D. Critton, Esq. rcritton@bc1claw.com
+
+Michael James Pike MPike@bcIclaw.com
+
+James brad@pathtojustice.com
+
+Isidro Manuel isidrogarcia@bellsouth.net
+
+Jack iph@searcvlaw.com Katherine Warthen Ezell KEzell@podhurst.com
+
+Paul G. Cassell cassellp@law.utah.edu
+
+Richard Horace Willits lawyerwillits@aol.com
+
+Robert C. Josefsberg rjosefsberg@podhurst.com
+
+# Via Facsimile and Regular Mail:
+
+Dave Lee Brannon, Esq. Federal Public Defender 450 S Australian Ave Ste 500 West Palm Beach, Florida 33401-5008 Fax: (561) 833-0368

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marker2/court-doe-v-epstein-80119/EFTA02748646/EFTA02748646.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CIV- 80893 — MARRA/
+
+JANE DOE,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+/
+
+## ORDER ON JOINT MOTION FOR AN EXTENSION OF TIME TO COMPLETE DISCOVERY
+
+This matter came before the Court upon the Defendant's and Plaintiff's Joint Motion for an Extension of Time to Complete Discovery. Having considered the motion and the agreement of counsel, it is
+
+ORDERED and ADJUDGED that the motion for extension is GRANTED as follows:
+
+A. New deadline to complete discovery: 04/16/2010
+
+DONE AND ORDERED this day of , 2010.
+
+Copies to all Counsel of Record
+
+KENNETH A. MARRA UNITED STATES DISTRICT JUDGE

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marker2/court-doe-v-epstein-80119/EFTA02748647/EFTA02748647.md

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+# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-C1V-80119-MARRA/MI
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related cases:
+
+08-80232, 08-08380, 08-80381, 08-80994,
+
+08-80993, 08-80811, 08-80893, 09-80469,
+
+09-80591, 09-80656, 09-80802, 09-81092
+
+I
+
+## JOINT MOTION FOR AN EXTENSION OF TIME TO COMPLETE DISCOVERY
+
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, and Plaintiff, JANE DOE, by and through her undersigned attorneys respectfully moves this Court for an extension of time to complete discovery deadlines, and as good cause in support of granting the motion, states as follows:
+
+- 1. This case is currently set on a two week trial docket commencing on July 19, 2010.
+- 2. The Amended Complaint filed by the Plaintiff is still the subject of aMotion to Dismiss filed on June 12, 2009 (DE 87). Thus, an Answer has not yet been filed.
+- 3. The majority of the deposition of Plaintiff has occurred; however, several witness depositions have yet to occur.
+
+Jane Doe v. Epstein, et al. Page 2
+
+4. The scheduling of depositions in this matter has become much more difficult since the case was consolidated on May 14, 2009, due to the number of attorneys involved and the fact that witnesses, plaintiffs and the defendant may only be deposed once. (See Order Consolidating Cases for Purpose of Discovery and Procedural Motions That Relate to Multiple Cases).
+
+5. Due the fact that depositions are still being scheduled, both Plaintiff and Defendant are in agreement with extending the discovery cutoff an additional two (2) week from April 2, 2010, making the new discovery cutoff date April 16, 2010.
+
+WHEREFORE, Plaintiff and Defendant request that this Court enter an order granting the Motion for Extension of Time to Complete Discovery
+
+# CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
+
+Counsel for the movant conferred via e-mail with counsel for the Plaintiff and counsel for the Plaintiff is in agreement with moving the above date.
+
+> By: /s/ Michael J. Pike MICHAEL J. PIKE, ESQ. Florida Bar #617296
+
+![](_page_1_Picture_8.jpeg)
+
+### Certificate of Service
+
+<sup>I</sup>HEREBY CERTIFY that atrue 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 by CM/ECF on this 19th day of February, 2010.
+
+Jane Doe v. Epstein, et al.  
+Page 3
+
+Respectfully submitted,
+
+By: /s/ Michael J. Pike
+
+ROBERT D. CRITTON, JR., ESQ.
+
+Florida Bar No. 224162
+
+rcrit@bclclaw.com
+
+MICHAEL J. PIKE, ESQ.
+
+Florida Bar #617296
+
+mpike@bclclaw.com
+
+BURMAN, CRITTON, LUTTIER & COLEMAN
+
+303 Banyan Blvd., Suite 400
+
+West Palm Beach, FL 33401
+
+561/842-2820 Phone
+
+561/515-3148 Fax
+
+*(Counsel for Defendant Jeffrey Epstein)*
+
+**Certificate of Service**  
+**Jane Doe No. 2 v. Jeffrey Epstein**  
+**Case No. 08-CV-80119-MARRA/...**
+
+Stuart S. Mermelstein, Esq.
+
+Adam D. Horowitz, Esq.
+
+Mermelstein & Horowitz, P.A.
+
+18205 Biscayne Boulevard
+
+Suite 2218
+
+Miami, FL 33160
+
+305-931-2200
+
+Fax: 305-931-0877
+
+ssm@sexabuseattorney.com
+
+ahorowitz@sexabuseattorney.com
+
+*Counsel for Plaintiffs*
+
+*In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994*
+
+Jack Alan Goldberger, Esq.
+
+Atterbury Goldberger & Weiss, P.A.
+
+250 Australian Avenue South
+
+Suite 1400
+
+West Palm Beach, FL 33401-5012
+
+[REDACTED], Jaffe, Weissing, [REDACTED] Fistos & Lehrman, PL
+
+425 N. Andrews Avenue
+
+Suite 2
+
+Fort Lauderdale, FL 33301
+
+Phone: 954-524-2820
+
+Fax: 954-524-2822
+
+brad@pathtojustice.com
+
+*Counsel for Plaintiff in Related Case No. 08-80893*
+
+Paul G. Cassell, Esq.
+
+*Pro Hac Vice*
+
+332 South 1400 E, Room 101
+
+Salt Lake City, UT 84112
+
+801-585-5202
+
+801-585-6833 Fax
+
+cassellp@law.utah.edu
+
+*Co-counsel for Plaintiff Jane Doe*
+
+Jane Doe v. Epstein, et al.
+
+Page 4
+
+561-659-8300
+
+Fax: 561-835-8691
+
+jazeso@bellsouth.net
+
+Counsel for Defendant Jeffrey Estein
+
+Isidro M. MN Esq.
+
+=Law Firm, P.A.
+
+224 Datura Street, Suite 900
+
+West Palm Beach, FL 33401
+
+561-832-7732
+
+561-832-7137 F
+
+isidrogarcia@bellsouth.net
+
+Counsel for Plaintiff in Related Case No. 08-
+
+80469

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marker2/court-doe-v-epstein-80119/EFTA02748651/EFTA02748651.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-cv-80119-MARRAJJOHNSON
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related cases:
+
+08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+## AGREED ORDER ON DEFENDANT EPSTEIN'S MOTION TO ATTEND MEDIATION JAS TO JANE DOE v. JEFFREY EPSTEIN, 08-CIV-808931
+
+This matter came before the Court on Defendant Epstein's Motion to Attend Mediation and Plaintiff's counsel being in agreement with the entry of this Order, it is HEREBY ORDERED and ADJUDGED that:
+
+The Court's No Contact Order (DE 238) shall not preclude Defendant, Jeffrey Epstein, from attending Plaintiff, Jane Doe's mediation or trial of this case.
+
+DONE and ORDERED this day of , 2010.
+
+Linnea R. United States Magistrate Judge
+
+Courtesy Copies: Judge Kenneth Marra Counsel of Record

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marker2/court-doe-v-epstein-80119/EFTA02748652/EFTA02748652.md

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+# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-cv-80119-MARRA/
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related cases:
+
+08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+### DEFENDANT EPSTEIN'S MOTION TO ATTEND MEDIATION AND MEMORANDUM IN SUPPORT THEREOF fAS TO JANE DOE v. JEFFREY EPSTEIN, 08-CIV-80893)
+
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, moves this Court for an order allowing him to attend mediation in the above-styled matter and as grounds set forth would state:
+
+- 1. The Court entered a no contact order which may apply to Jane Doe, DE
+- 238.
+- 2. Plaintiffs counsel and Plaintiff, Jane Doe have no objection to Mr. Epstein attending mediation and trial.
+- 3. Therefore, Defendant, Jeffrey Epstein, in an abundance of caution requests that the court enter the attached proposed Agreed Order which shall not preclude him from attending Jane Doe's mediation or the trial of this case.
+
+#### Rule 7.1 Certification
+
+Defense counsel has spoken with Plaintiff's counsel and he has no objectio to the entry of the proposed order.
+
+By: /s/ Michael J. Pike
+
+Robert D. Critton, Jr.
+
+Michael J. Pike
+
+Attorneys for Defendant Epstein
+
+# Certificate of Service
+
+<sup>I</sup>HEREBY 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 by electronic mail (e-mail) on this 19th day of February, 2010.
+
+Respectfully submitted,
+
+By: /s/ Michael J. Pike
+
+ROBERT D. CRITTON, JR., ESQ.
+
+Florida Bar No. 224162
+
+rcrit@bciclaw.com
+
+MICHAEL J. PIKE, ESQ.
+
+Florida Bar #617296
+
+mpike@bc1claw.com
+
+BURMAN, CRITTON, LUTHER & COLEMAN
+
+<sup>303</sup>Banyan Blvd., Suite <sup>400</sup>
+
+West Palm Beach, FL 33401
+
+561/842-2820 Phone
+
+561/515-3148 Fax
+
+(Counsel for Defendant Jeffrey Epstein)
+
+# Certificate of Service Jane Doe No. 2 v. Jeffrey E • Case No. 08-CV-80119-MARRA
+
+Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ssm@sexabuseattomey.com ahorowitz@sexabuseattomev.com Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jaaeso®bellsouth.net Counsel for Defendant Jeffrey Estein
+
+, Jaffe, Weissing,M, Fistos & Lehrman, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 brad@pathtojustice.com Counsel for Plaintiff in Related Case No. 08-80893
+
+Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax cassellpalaw.utah.edu Co-counsel for Plaintiff Jane Doe
+
+Isidro M. ME, Esq. Law Finn, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidrozarcia bellsouth.net Counsel for Plaintiff in Related Case No. 08-80469

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marker2/court-doe-v-epstein-80119/EFTA02748655/EFTA02748655.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-cv-80119-MARRA/JOHNSON
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related cases:
+
+08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+## AGREED ORDER ON DEFENDANT EPSTEIN'S MOTION TO ATTEND MEDIATION (AS TO JANE DOE v. JEFFREY EPSTEIN. 08-CIV-80893)
+
+This matter came before the Court on Defendant Epstein's Motion to Attend IDE 471) Mediation and Plaintiff's counsel being in agreement with the entry of this Order, it is
+
+HEREBY ORDERED and ADJUDGED that:
+
+The Court's No Contact Order (DE 238) shall not preclude Defendant, Jeffrey Epstein, from attending Plaintiff, Jane Doe's mediation or trial of this case.
+
+DONE and ORDERED this if ctierday of cettny , 2010.
+
+ti.4.40 r -70 A • frnAtf.4 United States Magistrate Judge
+
+Courtesy Copies: Judge Kenneth Marra Counsel of Record

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marker2/court-doe-v-epstein-80119/EFTA02748656/EFTA02748656.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CIV- 80893 — MARRA/EMI
+
+JANE DOE,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## ORDER ON JOINT MOTION FOR AN EXTENSION OF TIME TO COMPLETE DISCOVERY
+
+This matter came before the Court upon the Defendant's and Plaintiff's Joint Motion for (DE 07th an Extension of Time to Complete Discovery?' Having considered the motion and the agreemen<sup>t</sup> of counsel, it is
+
+ORDERED and ADJUDGED that the motion for extension is GRANTED as follows:
+
+A. New deadline to complete discovery: 04/16/2010
+
+DONE AND ORDERED this / 9 r day of F&bruCk.C14/8 , 2010.
+
+KENNETH A. MARRA UNITED STATES DISTRICT JUDGE
+
+Copies to all Counsel of Record

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marker2/court-doe-v-epstein-80119/EFTA02748657/EFTA02748657.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CV-80119-MARRAa
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related Cases:
+
+08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092,
+
+## PLAINTIFFS JANE DOE NOS. 2-S'S NOTIFICATION OF 90 DAYS EXPIRING ON MOTION TO COMPEL
+
+Plaintiffs Jane Doe Nos. 2-8, by and through undersigned counsel and pursuant to Local Rule 7.1.B.3, hereby give notice that a motion in this case has been pending and fully briefed for a period of ninety (90) days, as follows:
+
+- I. On September 30, 2009, Plaintiffs Jane Doe Nos. 2-8 filed a Motion to Compel Responses to Requests for Net Worth Discovery and Incorporated Memorandum of Law (D.E. 333).
+- 2. Defendant Jeffrey Epstein filed his response to the Plaintiffs' Motion to Compel on November 2, 2009 (D.E. 390).
+- 3. Plaintiffs Jane Doe Nos. 2-8 filed their reply to Defendant Epstein's response on November 23, 2009 (D.E. 426).
+
+- 4. No hearing has been held or scheduled on the Motion.
+- 5. Plaintiffs calculate that the applicable ninety day period expired on February 22, 2010.
+- 6. Plaintiffs' counsel file this Notification for purposes of compliance with the duty of movant's counsel set forth in S.D.Fla.L.R. 7.1 B.3.
+
+Respectfully submitted,
+
+By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) ssm@sexabuseattorney.com Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattorney.com MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: (305) 931-2200 Fax: (305) 931-0877
+
+## CERTIFICATE OF SERVICE
+
+I hereby certify that on February 23, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+/s/ Stuart S. Mermelstein
+
+## SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida
+
+Jack Alan Goldberger, Esq. igoldberger@agwpa.com
+
+Robert D. Critton, Esq. rcritton@bciclaw.com
+
+James brad@pathtojustice.com
+
+Isidro Manuel isidrogarcia@bellsouth.net
+
+Jack jph@searcylaw.com U
+
+Katherine Warthen Ezell KEzell@podhurst.com
+
+Michael James Pike MPike@bciclaw.com
+
+Paul G. Cassell cassellp@law.utah.edu
+
+Richard Horace Willits lawyerwillits@aol.com
+
+Robert C. Josefsberg rjosefsberg@podhurst.com

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marker2/court-doe-v-epstein-80119/EFTA02748660/EFTA02748660.md

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+[REDACTED]
+
+[REDACTED]  
+[REDACTED]
+
+**From:** "Brad [REDACTED]" <[brad@pathtojustice.com](mailto:brad@pathtojustice.com)>  
+**Date:** February 26, 2010 9:30:19 AM MST  
+**To:** "Jack Goldberger" <[jgoldberger@agwpa.com](mailto:jgoldberger@agwpa.com)>  
+**Subject:** RE: Nadia depo
+
+I will call you today sometime but I am tied up most of the day. All attorneys cross-noticed the depo for Monday and it has been on for awhile, so we will need to get a date in the very near future that works for everyone's schedule, and as you know that is not easy to do. Like I said, I will call you at my first opportunity today but this is not completely in my control.
+
+Brad [REDACTED]  
+Civil Justice Attorney  
+[REDACTED], Jaffe, Weissing,  
+[REDACTED], Fistos & Lehrman, P.L.  
+425 North Andrews Avenue, Suite 2  
+Fort Lauderdale, Florida 33301  
+Telephone: 954-524-2820  
+Facsimile: 954-524-2822  
+[pathtojustice.com](http://pathtojustice.com)
+
+-----Original Message-----
+
+**From:** Jack Goldberger [mailto:jgoldberger@agwpa.com]  
+**Sent:** Thursday, February 25, 2010 7:44 PM  
+**To:** Brad [REDACTED]  
+**Subject:** Nadia depo
+
+Brad
+
+I left u a message and didn't hear back from u. I have hearings on my lake county cap sex battery case set next week in conflict with Nadia depo. Please call me on cell to set another date. [REDACTED]  
+Jack
+
+Sent from my iPhone
+
+EXHIBIT A

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marker2/court-doe-v-epstein-80119/EFTA02748661/EFTA02748661.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CIV-80119-MARRA/Ja
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related cases:
+
+08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+## MOTION FOR PROTECTIVE ORDER AS TO THE DEPOSITION OF
+
+Third-Party Witness, by and through her undersigned attorney, Jack A. Goldberger, and pursuant to Fed. R. Civ. P. 26(c), moves for a Protective Order to rescheduled her deposition currently set for Monday, March 1, 2010 and states:
+
+1. On February 3, 2010, counsel for Plaintiff, Jane Doe, filed a Notice of Taking the Deposition of Third-Party Witness, in a related State Court action filed against Mr. Epstein. While the Notice is filed in L.M. v. Jeffrey Epstein, Palm Beach County Circuit Court Case No: 502008CA028051AXXXMB, counsel for Plaintiff, Jane Doe, intends to utilize this deposition in Jane Doe's Federal Court action. Further, counsel for Plaintiffs, Jane Does 2-8 have filed a Cross-Notice of Taking Depositions as to
+
+2. As the court is well aware, the scheduling of depositions in these cases has been difficult given the fact that there are several plaintiffs represented by several attorneys and this court, by way of its Consolidation Order, dictates that depositions should only be taken one time. To date, the parties have done their best to work together in coordinating the depositions in which it is apparent that all of the plaintiffs' attorneys will want to be present.
+
+3. While March 1, 2010 is a previously agreed upon date provided by the undersigned for the deposition of the undersigned now has a conflict that prevents his attendance on March 1, 2010.
+
+4. Undersigned counsel is representing the Defendant in State of Florida v. Esterson, Case No: 2009CF2114A02, before the Honorable Judge 1■ **in a Capital Sexual Battery case out of Lake County, Florida. If convicted, the Defendant faces a potential life sentence. Counsel for Plaintiff, Jane Doe, and counsel for Plaintiffs, Jane Does 2-8, are aware of the pending case in Lake County, Florida, and the fact that there may potentially be some scheduling issues with respect to same.** 
+
+**5. State of Florida v. Esterson was originally scheduled for trial on March 7, 2010. The case has now been rescheduled for trial on April 5, 2010. However, the undersigned must travel to Lake County, Florida on March 1, 2010 (upon his return to Florida) with an expert witness to meet with the Defendant and prepare for the Pretrial Evidentiary Hearing scheduled for March 3, 2010.** 
+
+**6. Undersigned counsel contacted counsel for Plaintiff, Jane Doe, via email and telephone on February 24 and February 25, 2010 detailing the circumstances surrounding the need to reschedule the deposition of providing additional available dates wherein both the undersigned and will be available.** 
+
+7. It should also be noted that the undersigned is currently out of town on a planned vacation in Colorado and is making every attempt to resolve the current scheduling conflict.
+
+8. Counsel for Plaintiff, Jane Doe, contacted the undersigned via email on February 26, 2010 indicating that "the deposition has been set for a while and has been cross-noticed by other parties, and therefore is not completely in his control" See Attached Exhibit A.
+
+9. Out of an abundance of caution, the undersigned is filing this protective order as to the deposition of Third-Party Witness . The undersigned, at his earliest availability, will contact all interested parties and coordinate a new date for the deposition of
+
+WHEREFORE, Third-Party Witness, , respectfully requests the Court enter a protective order allowing her deposition to be rescheduled from March 1, 2010, to another date to be agreed upon by all interested parties.
+
+> Is/ Jack A. Goldberger Jack A. Goldberger, Esq. Third-Party Witness,
+
+## Certificate of Service
+
+I HEREBY 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 by electronic mail (email) on this 26th day of February, 2010.
+
+Respectfully submitted,
+
+By: /s/ Jack A. Goldberger  
+JACK A. GOLDBERGER, ESQ.  
+Florida Bar No. 262013  
+[jgoldberger@agwpa.com](mailto:jgoldberger@agwpa.com)  
+ATTERBURY GOLDBERGER & WEISS, PA  
+250 Australian Avenue South  
+Suite #1400  
+West Palm Beach, FL 33401
+
+**Certificate of Service**  
+**Jane Doe No. 2 v. Jeffrey Epstein**  
+**Case No. 08-CV-80119-MARRA** [REDACTED]
+
+Stuart S. Mermelstein, Esq.  
+Adam D. Horowitz, Esq.  
+Mermelstein & Horowitz, P.A.  
+18205 Biscayne Boulevard  
+Suite 2218  
+Miami, FL 33160  
+305-931-2200  
+Fax: 305-931-0877  
+[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com)  
+[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com)
+
+*Counsel for Plaintiffs*  
+*In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994*
+
+Robert D. Critton, Jr.  
+Burman Critton Luttier & Coleman, LLP  
+303 Banyan Blvd.  
+Suite 400  
+561-842-2820  
+561-844-6929  
+West Palm Beach, FL 33401  
+*Counsel for Defendant, Jeffrey Epstein*
+
+[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, PL  
+425 N. Andrews Avenue  
+Suite 2  
+Fort Lauderdale, FL 33301  
+Phone: 954-524-2820  
+Fax: 954-524-2822  
+[brad@pathtojustice.com](mailto:brad@pathtojustice.com)  
+*Counsel for Plaintiff in Related Case No. 08-80893*
+
+Paul G. Cassell, Esq.  
+*Pro Hac Vice*  
+332 South 1400 E, Room 101  
+Salt Lake City, UT 84112  
+801-585-5202  
+801-585-6833 Fax  
+[cassellp@law.utah.edu](mailto:cassellp@law.utah.edu)  
+*Co-counsel for Plaintiff Jane Doe*
+
+Isidro M. [REDACTED], Esq.  
+[REDACTED] Law Firm, P.A.  
+224 Datura Street, Suite 900  
+West Palm Beach, FL 33401  
+561-832-7732  
+561-832-7137 F  
+[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net)
+
+Counsel for Plaintiff in Related Case No. 08- 80469

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marker2/court-doe-v-epstein-80119/EFTA02748666/EFTA02748666.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CIV-80119-MARRai
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related cases:
+
+08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+## ORDER ON DEFENDANT EPSTEIN'S MOTION TO EXCEED PAGE LIMITATION BY TWO PAGES IN DEFENDANT'S, MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL OF PORTIONS OF THE MAGISTRATE'S ORDER DATED FEBRUARY 4, 2010 (DE 462), WITH INCORPORATED OBJECTIONS AND MEMORANDUM
+
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion to Exceed Page Limitation by only two (2) pages in his Motion for Reconsideration and/or Request for Rule 4 Review and Appeal of Portions of the Magistrate's Order dated February 4, 2010 (DE 462) with Incorporated Objections and Memorandum. Having considered Defendant's motion to exceed page limitation by two (2) substantive pages, it is HEREBY ORDERED and ADJUDGED that:
+
+Defendant's motion is GRANTED. Defendant's Motion for Reconsideration and/or Request for Rule 4 Review and Appeal of Portions of the Magistrate's Order dated February 4, 2010 (DE 462) with Incorporated Objections and Memorandum may exceed 20 pages by two (2) additional pages
+
+DONE and ORDERED this day of , 2010.
+
+Kenneth A. Marra United States District Judge
+
+Courtesy Copies: Counsel of Record

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marker2/court-doe-v-epstein-80119/EFTA02748668/EFTA02748668.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CIV-80119-MARRA/.
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related cases:
+
+08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+## DEFENDANT EPSTEIN'S MOTION TO EXCEED PAGE LIMITATION BY TWO PAGES IN DEFENDANT'S, MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL OF PORTIONS OF THE MAGISTRATE'S ORDER DATED FEBRUARY 4,2010 IDE 462), WITH INCORPORATED OBJECTIONS AND MEMORANDUM
+
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, moves to exceed the page limitation of 20 pages by only two (2) pages for the Rule 4 Review and Appeal of Portions of the Magistrate's Order dated February 4, 2010 (DE 462) with Incorporated Objections and Memorandum. In support of his motion, Defendant states:
+
+1. In order to present Defendant's Motion in an organized and understandable manner, the 20 page limitation is required to be exceeded by two (2) pages of substantive argument.
+
+2. The undersigned does not believe that Plaintiff, Jane Doe, will have an objection to this Motion.
+
+WHEREFORE, Defendant respectfully requests that this Court grant Defendant's motion, and enter an order allowing the Motion to exceed the maximum limit of 20 pages by two (2) pages, making the total number of pages twenty-two 2), substantive pages.
+
+> By: MICHA ESQ. Florid ar #617296
+
+## Certificate of Service
+
+<sup>I</sup>HEREBY CERTIFY that atrue 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 by CM/ECF on this 26th day of February, 2010.
+
+Respectfully su d,
+
+By: ROBERT ON, JR., ESQ.
+
+Florida B No. 224 .2
+
+rcri claw.corn
+
+MICH L J. PIKE, ESQ.
+
+Florida Bar #617296
+
+mvike@bc1claw.com
+
+BURMAN, CRITTON, LUTTIER & COLEMAN
+
+515 N. Flagler Drive, Suite 400
+
+West Palm Beach, FL 33401
+
+561/842-2820 Phone
+
+561/515-3148 Fax
+
+(Counsel for Defendant Jeffrey Epstein)
+
+## Certificate of Service Jane Doe No. 2 v. Jeffrey Case No. 08-CV-80119-MA
+
+Stuart S. Mermelstein, Esq.
+
+Adam D. Horowitz, Esq.
+
+Merrnelstein & Horowitz, P.A.
+
+<sup>18205</sup>Biscayne Boulevard
+
+Suite 2218
+
+Miami, FL 33160
+
+305-931-2200
+
+Fax: 305-931-0877
+
+ssm@sexabuseattomev.com
+
+ahorowitz@sexabuseattorney.com
+
+Counsel for Plaintiffs
+
+In related Cases Nos. 08-80069, 08-80119,
+
+08-80232, 08-80380, 08-80381, 08-80993,
+
+08-80994
+
+Jack Alan Goldberger, Esq.
+
+Atterbury Goldberger & Weiss, P.A.
+
+250 Australian Avenue South
+
+Suite 1400
+
+West Palm Beach, FL 33401-5012
+
+561-659-8300
+
+Fax: 561-835-8691
+
+iazes4bellsouth.net
+
+Counsel for Defendant Jeffrey Estein
+
+, Jaffe, Weissing,M, Fistos
+
+& Lehrman, PL
+
+425 N. Andrews Avenue
+
+Suite 2
+
+Fort Lauderdale, FL 33301
+
+Phone: 954-524-2820
+
+Fax: 954-524-2822
+
+brad@pathtoiustice.com
+
+Counsel for Plaintiff in Related Case No.
+
+08-80893
+
+Paul G. Cassell, Esq.
+
+Pro Hac Vice
+
+332 South 1400 E, Room 101
+
+Salt Lake City, UT 84112
+
+801-585-5202
+
+801-585-6833 Fax
+
+cassellp@law.utah.edu
+
+Co-counsel for Plaintiff Jane Doe
+
+, Esq.
+
+Law Firm, P.A.
+
+224 Datura Street, Suite 900
+
+West Palm Beach, FL 33401
+
+561-832-7732
+
+561-832-7137 F
+
+isidrozarciaQbellsouth.net
+
+Counsel for Plaintiff in Related Case No.
+
+08-80469
+
+Robert C. Josefsberg, Esq.
+
+Katherine W. Ezell, Esq.
+
+Podhurst Orseck, P.A.
+
+<sup>25</sup>West Flagler Street, Suite <sup>800</sup>
+
+Miami, FL 33130
+
+305 358-2800
+
+Fax: 305 358-2382
+
+riosefsbernapodhurst.com
+
+kezellapodhurstcom
+
+Counsel for Plaintiffs in Related Case

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marker2/court-doe-v-epstein-80119/EFTA02748671/EFTA02748671.md

@@ -0,0 +1,210 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO: 08-CV-80893-MARRALME
+
+JANE DOE,
+
+Plaintiff
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant
+
+# PLAINTIFF'S FIRST REOUEST FOR PRODUCTION TO DEFENDANT
+
+COMES NOW the Plaintiff, JANE DOE, by and through her undersigned counsel, pursuant to Fed.R.Civ.P. 34 and S.D. Fla. 26.10., and requests the Defendant, Jeffrey Epstein, to produce the original or best copy of the items listed hereinbelow, at the offices of the Plaintiffs undersigned counsel, for inspection and/or copying within thirty (30) days of service.
+
+### PRELIMINARY STATEMENT
+
+1. These requests for production are deemed continuing. Pursuant to Rule 26(e) of the Federal Rules of Civil Procedure and applicable law, if any information sought by said requests for production is not learned until after they are answered, or if any answers for any reason should later become incorrect, there shall be a continuing duty on the party answering said requests to supplement or change answers previously submitted.
+
+### DEFINITIONS AND INSTRUCTIONS
+
+1. Communication. The term "communication" means the transmittal of information (in the form of facts, ideas, inquiries or otherwise).
+
+2. Document. The term "document" is defined to be synonymous in meaning and equal in scope to the usage of this term in Federal Rule of Civil Procedure 34(a), including, without limitation, electronic or computerized data compilations. A draft or non-identical copy is <sup>a</sup> separate document within the meaning of this term.
+
+EFTA02748671
+
+- 3. Identify (with respect to person). When referring to a person, "to identify" means to give, to the extent known, the person's full name, present or last known address, and when referring to anatural person, additionally, the present or last known place of employment. Once aperson has been identified in accordance with this subparagraph, only the name of the person need be listed in response to subsequent discovery requesting the identification of that person.
+- 4. Identify (with respect to documents). When referring to documents, "to identify" means to give, to the extent known, the (i) type of documents; (ii) general subject matter; (iii) date of the document; and (iv) author(s), addressee(s) and recipient(s).
+- 5. Parties. The terms "plaintiff' and "defendant" as. well as <sup>a</sup>party's full or abbreviated name or a pronoun referring to a party means the party and, where applicable, its officers, directors, employees, partners, corporate parent, subsidiaries or affiliates. This definition is not intended to impose a discovery obligation on any person who is not a party to the litigation.
+- 6. Person. The term "person" is defined as any natural person or any business, legal or governmental entity or association.
+- 7. Concerning. The term "concerning" means relating to, referring to, describing, evidencing or constituting.
+- 8. All/Each. The terms "all" and "each" shall be construed as all and each.
+- 9. And/Or. The connectives "and" and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the discovery request all responses that might otherwise be construed to be outside of its scope.
+- 10. Number. The use of the singular form of any word includes the plural and vice versa.
+- 11. Refer/Relate to. "Refer" or "relate to" means to make astatement about, discuss, describe, reflect, constitute, identify, deal with, consist of, establish, comprise, list, evidence, substantiate or in any way pertain, in whole to in part, to the subject.
+- 12. As used herein the singular shall include the plural, the plural shall include the singular, and the masculine, feminine and neuter shall include each of the other genders.
+
+# DOCUMENTS REQUESTED
+
+- 1. Copies of all telephone records in your or your attorneys' possession from 2002 <sup>2005</sup>that in any way relate to you (including all phone lines owned by you or that were used to contact girls for the purposes of scheduling massages for you).
+
+2. All massage appointment books, diaries, computer calendars or scheduling entries, scheduling books or any other writing or correspondence that contains the names of any of the girls that were called, contacted, scheduled, or who otherwise went to your home located at 358 El Brillo Way, Palm Beach, Florida, for the purpose of giving you <sup>a</sup>massage.
+
+3. Any and all documentation in your possession that contains Plaintiffs name or that refers to Plaintiff, directly or indirectly, (includes emails, letters, message pads, diaries, appointment books, computer print outs).
+
+4. Any and all photos, videos, downloaded digital prints or any other visual depiction of Plaintiff, or of any other known or suspected minor females introduced to you, directly or indirectly, by Plaintiff.
+
+5. Photos of the inside of your home located at 358 El Brillo Way, Palm Beach, Florida, that depict the room(s) where the massages took place (including massage table).
+
+6. Any and all documentation of cancelled checks or evidence of payment to Plaintiff of any kind and for any reason whatsoever.
+
+7. All discovery information obtained by you or your attorneys as <sup>a</sup>result of the exchange of discovery in the State criminal case against you or the Federal investigation against you.
+
+8. All financial documents evidencing asset transfers from 2005 to the present for you personally or any company or corporation owned by you.
+
+9. Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors.
+
+10. All correspondence between you or your attorneys and state or federal law enforcement or . prosecutors (includes, but is not limited to, letters to and from the State Attorney's office or any agents thereof).
+
+11. Any and all documents reflecting your current net worth.
+
+12. Personal tax returns for all years from 2002 through the present.
+
+13. A photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements.
+
+14. A sworn statement of your net worth (including adetailed financial statement depicting all current assets and liabilities).
+
+IS. All financial statements or affidavits produced by you for any reason, to any person, company, entity or corporation since 2005.
+
+16. All medical records of Defendant Epstein from Dr. Stephan Alexander.
+
+### CERTIFICATE OF SERVICE
+
+WE HEREBY CERTIFY that atrue and correct copy of the above and foregoing has been provided via United States mail to the following addressees, this 13day of March, 2009.
+
+Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, Luttier & Coleman, LLP 515 North Flagler Drive Suite 400 West Palm Beach, Florida 33401 rcrit@bciclaw.com mpike©bciclaw.com
+
+Jack Alan Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 jageso®bellsouth.net
+
+Michael R. Tein, Esquire Tein, P.L. 3059 Grand Avenue Suite 340 Coconut Grove, Florida 33133 teindtlewistein.com
+
+Respectfully Submitted,
+
+THE LAW OFFICE OF BRAD ASSOCIATES, LLC
+
+By:
+
+Brad Esquire Attorney for Plaintiff Florida Bar No. 542075 2028 Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 Facsimile: 954-924-1530 E-Mail: be@bradedwardslaw.com
+
+Paul G. Cassell Attorney for Plaintiff Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 <sup>E</sup>-Mail: cassellp@law.utah.edu
+
+JANE DOE,
+
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CIV- 80893 — MARRAIla
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant. /
+
+## DEFENDANT'S RESPONSE & OBJECTIONS TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION (dated 03/23109)
+
+Defendant, JEFFREY EPSTEIN, ('EPSTEIN"), by and through his undersigned attorneys, pursuant to Fed.R.Civ.P., 34, and S.D. Fla. 26.1.G., serves his response to Plaintiff JANE DOE's First Request For Production, dated March 23, 2009.
+
+Request No. 1: Copies of all telephone records in your or your attorneys' possession from 2002 through 2005 that in any way relate to you (including all phone lines owned by you or that were used to contact girls for the purposes of scheduling massages for you.)
+
+Response: Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution.
+
+Request No. 2: All massage appointment books, diaries, computer calendars or scheduling entities, scheduling books or any other writing or correspondence that contains the names of any of the girls that were called, contacted, scheduled or who
+
+otherwise went to your home located at 358 El Brillo Way, Palm Beach, Florida, for the purpose of giving you a massage.
+
+**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution.
+
+**Request No. 3:** Any and all documentation in your possession that contains Plaintiff's name or that refers to Plaintiff, directly or indirectly, (includes e-mails, letters, message pads, diaries, appointment books, computer print outs).
+
+**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution.
+
+**Request No. 4:** Any and all photos, videos, downloaded digital prints or any other visual depiction of Plaintiff, or of any other known or suspected minor females introduced to you, directly or indirectly, by Plaintiff.
+
+**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution.
+
+**Request No. 5:** Photos of the inside of your home located at 358 El Brillo Way, Palm Beach, Florida, that depict the room(s) where the massages took place (including massage table).
+
+**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution.
+
+**Request No. 6:** Any and all documentation of cancelled checks or evidence of payment to Plaintiff of any kind and for any reason whatsoever.
+
+**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution.
+
+**Request No. 7:** All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you.
+
+**Response:** Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible
+
+pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence <sup>410</sup>and 408, and §90.410, Fla. Stat. Further, the request may include information subject to work product or an attorney-client privilege.
+
+Request No. 8: All financial documents evidencing asset transfers from 2005 to the present for you personally or any company or corporation owned by you.
+
+Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and <sup>I</sup> must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution.
+
+Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors.
+
+Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and <sup>I</sup> must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence <sup>410</sup>and 408, and §90.410, Fla. Stat. Further, the request may include information subject to work product or an attorney-client privilege.
+
+Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the State Attorney's office or any agents thereof).
+
+**Response:** Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further, the request may include information subject to work product or an attorney-client privilege.
+
+**Request No. 11:** Any and all documents reflecting your current net worth.
+
+**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution.
+
+**Request No. 12:** Personal tax returns for all years from 2002 through the present.
+
+**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad.
+
+**Request No. 13:** A photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2020 and 2008,
+
+including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements.
+
+**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional protections and privileges, the scope of information is so overbroad that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence; compiling such information over a six year period would be unduly burdensome and time consuming.
+
+**Request No. 14:** A sworn statement of your net worth (including a detailed financial statement depicting all current assets and liabilities).
+
+**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution.
+
+**Request No. 15:** All financial statements or affidavits produced by you for any reason, to any person, company, entity or corporation since 2005.
+
+**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad.
+
+Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander.
+
+Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and <sup>I</sup> must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution.
+
+# Certificate of Service
+
+WE HEREBY CERTIFY that a true copy of the f Mail and facsimile to the following addressees this regoing has been sent via U.S. day of May, 2009.
+
+Brad Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 bedwards( rra-law.com Counsel for Plaintiff Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax casselloelaw.utah.edu Co-counsel for Plaintiff
+
+Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 561-835-8691 Fax jaqesqabellsouth.net Co-Counsel for Defendant Jeffrey Epstein
+
+Respectfully subm
+
+RITTON, JR., ESQ.
+
+Florida Bar No. 224162
+
+rcrit bciclaw.com
+
+BURMAN, CRI1TON, LUTTIER & COLEMAN
+
+<sup>515</sup>N. Flagler Drive, Suite 400
+
+West Palm Beach, FL 33401
+
+561/842-2820 Phone
+
+561/515-3148 Fax
+
+(Counsel for Defendant Jeffrey Epstein)

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marker2/court-doe-v-epstein-80119/EFTA02748684/EFTA02748684.md

@@ -0,0 +1,280 @@
+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+CASE NO.: 08-CIV-80119-MARRAall
+
+Related cases:
+
+08-80232, 08-08380, 08-80381, 08-80994,
+
+08-80993, 08-80811, 08-80893, 09-80469,
+
+09-80591, 09-80656, 09-80802, 09-81092
+
+### DEFENDANT'S, MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL OF PORTIONS OF THE MAGISTRATE'S ORDER DATED FEBRUARY 4, 2010 (DE 462), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW
+
+Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and Appeal of Portions of the Magistrate's Order (DE 462) pursuant to Rule 60, Fed.R.Civ.P. Rule 4, Rule 4(c) and Fed. R. Civ. P. 53(e). In support, Epstein states:
+
+#### I. Procedural Background
+
+Plaintiff's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth therein are incorporated herein by reference as if completely set forth herein as each apply to request numbers 10, 12 and 13.
+
+Significantly, these cases have been consolidated for discovery. Therefore, consistent rulings must apply. In making those rulings, this Court must continue to recognize that the allegations in the related cases cannot be forgotten. (Eg., see DE 242, 293, and 462). Production of information in one case could provide alink in the chain of evidence used to prosecute Epstein for acrime or provide an indirect link to incriminating evidence in another case and in another jurisdiction. Id. and infra.
+
+The Request for Production and the responses thereto are attached as Composite Exhibit "A".
+
+#### H. The Fifth Amendment
+
+The Fifth Amendment serves as <sup>a</sup>guarantee against testimonial compulsion and provides, in relevant part, that "[njo person...shall be compelled in any Criminal Case to be awitness against himself." (DE 242, p.5); see also Edwin v. Price, <sup>778</sup>F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, <sup>414</sup>U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right and extends not only to answers that would support acriminal conviction, but extends also to those answers which would furnish alink in the chain of evidence needed to prosecute the claimant for acrime. See Hoffman v. United States, <sup>341</sup>U.S. 479, <sup>486</sup> (1951). Information is protected by the privilege not only if it would support acriminal conviction, but also in those instances where "the responses would merely `provide alead or clue' to evidence having a tendency to incriminate." See United States v. Neff, <sup>315</sup>F.2d 1235, <sup>1239</sup>(9th Cir.), cat denied, <sup>447</sup>U.S. 925 (1980); Blau v. United States, <sup>340</sup>U.S. 159 (1950); SEC vLeach <sup>156</sup>F.Supp.2d 491, 494 (E.D. PA. 2001).
+
+Moreover, the act of production itself may implicitly communicate statements and, for this reason, the Fifth Amendment privilege also encompasses the circumstances where the act of producing documents in response to a subpoena or production request has a compelled testimonial aspect. See United States v. Hubbell, <sup>530</sup>U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly authenticate" the requested documents, the act of producing responsive documents is considered testimonial and is protected by the Fifth Amendment. See In re Grand Jury Subpoena, <sup>I</sup>F.3d 87, 93 (2nd Cir. 1993); Rudy-Glanzer v. Glanzer, <sup>232</sup>F.3d 1258, 1263 (9th Cir. 2000)(the "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of prosecution and also covers those circumstances where the disclosures would not be directly incriminating, but could provide an indirect link to incriminating evidence).
+
+# III. The Requests For Production, Argument And Memorandum Of Law
+
+## a. Requests Numbers 7, 9 and <sup>10</sup>
+
+Request No. 7: All discovery information obtained by you or your attorneys as <sup>a</sup>result of the exchange of discovery in the State criminal case against you or the Federal investigation against you.
+
+Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors.
+
+Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the State Attorney's office or any agents thereof).
+
+Response to Request Numbers 7, 9 and 10: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accep<sup>t</sup> this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further, the reques<sup>t</sup> may include information subject to work product or an attorney-client privilege.
+
+In light of the Court's Order and the Reply which further defines exactly what Plaintiff seeks (DE 354, p. 3), Epstein is now permitted to cautiously elaborate on his responses.
+
+As to Request Number 7, Epstein and his attorneys do not have any "discovery information" provided to them by the federal government.'
+
+As to Request Number 9, Epstein has not been given any evidentiary materials or evidentiary documents by the federal government.
+
+Request No. 10 contravenes the critical public policy of encouraging the resolution of criminal prosecutions without trial and the concomitant understanding that defendants will be considerably more likely to engage in full and discussions with the government if they need not fear that statements they or their counsel make to government prosecutors will be used against them to their detriment. The critical importance of plea bargaining to the criminal justice system has long been recognized. "[W]hatever might be the situation in an ideal world, the fact is that the guilty plea and the often concomitant plea bargain are important components of this country's criminal justice system. Properly administered, they can benefit all concerned." Bordenkircher v. Haves, <sup>434</sup>U.S. 357, 361-62 (1978), quoting Blackledge v. Allison, <sup>431</sup>U.S. 63, 71 (1977). To encourage defendants to participate in the plea negotiation process, rules have developed to prohibit admission into evidence against the defendant of any and all statements he or his counsel acting on his behalf makes to government prosecutors during the plea negotiation process. This confidentiality protection is embodied in both Fed. R. Evid. 410 and Fed. R. Crim. P. 11(f). While these rules by their express terms refer only to admissibility of evidence, the
+
+As set forth infra, the federal government provided Epstein with the NPA and the list attached thereto. The NPA is now <sup>a</sup>public document and the list, pursuant to Brad Edward's Agreement with Judge J. Colbath, remains confidential.
+
+<sup>2</sup>FRE 410(4) is particularly directed to communications in matters which, like Epstein's, did not result in aplea of guilty to at tx federal charge. Fla. Stat. §90.410 provides parallel protections in state criminal matters.
+
+purposes and policies underlying these rules in instructive in this context, in which acivil <sup>p</sup>laintiff seeks discovery of documents falling within the scope of these two rules.
+
+Rule 410 was created to promote active plea negotiations and plea bargains, which our Supreme Court has acknowledged are "important components of this country's criminal justice system.". . . Our Court of Appeals has held that "in order for plea bargaining to work effectively and fairly, adefendant must be free to negotiate without fear that this statements will later be used against him.". Indeed, absent the protection of Rule 410, "the possibility of self-incrimination would discourage defendants from being completely candid and open during plea negotiations."
+
+<sup>534</sup>F.Supp.2d 63, 66-67 (D.D.C. 2008), quoting United States v. <sup>617</sup> F.2d 677, 683 (D.C.Cir. 1980). See Lg., United States v. Mezzanatto, <sup>513</sup>U.S. 196, 205, <sup>207</sup> (1995)(purpose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, <sup>a</sup> privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence ¶410[05] at 410-43 (1994)); United States v. Barrow, <sup>400</sup>F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is to promote plea negotiations by permitting defendants to talk to prosecutors without sacrificing their ability to defend themselves if no disposition agreement is reached"); Fed. R. Crim. P. 11, Advisory Committee Notes, 1979 Amendment ("the purpose of Fed. R. Ev. 410 and Fed. R. Crim. P. 11(e)(6) [now Rule 11(f)] is to promote the unrestrained candor which produces effective plea discussions").<sup>3</sup>
+
+Additional illustration of the high degree of confidentially accorded settlement negotiations is found in Fed. R. Evid. 408, which precludes the introduction into evidence communications made during settlement negotiations. The purposes underlying Rule 408 are essentially the same as those underlying Rules 11(1) and 410: "to encourage non-litigious solutions to disputes." Reichenbach v. MB 528 F.2d 1072, 1074 (11th Cir. 1976). Sse, Lg., Stockman v. Oakcrest Dental Center P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose underlying Rule 408 . . . is the promotion of the public policy favoring the compromise and settlement of disputes that would otherwise be discouraged with the admission of such evidence"); Bankcard America, Inc. v. Universal Bancard Systems, Inc., <sup>203</sup>F.3d 477, 483 (7th Cir. 2000)("Because settlement talks might be chilled if such discussions could later be used as admissions of liability at trial, the rule's purpose is to encourage settlements"); In re A.H. Robins Co Inc., 197 B.R. 568, 572 (E.D.Va. 1994)("Rule 408 aims to settlement discussions in an individual lawsuit, and therefore insulates the particular parties to asettlement discussion from possible adverse consequences of their and open statements"). So crucial is this policy of confidentiality to the functioning of our federal court system that some courts have held that communications falling within the parameters of Rule 408 are covered by asettlement privilege which insulates them not just from admission into evidence but from discovery as well. See, Lg., Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., <sup>332</sup>F.3d 976, 979-983 (6th Cir. 2003).
+
+Given the powerful and long-standing policy of according confidentiality to settlement negotiations in both the civil and criminal context, civil plaintiffs should, at a minimum, be required to demonstrate real and concrete need for the material. They should not be permitted to rummage through such sensitive documents based on nothing more than a vague and contentless statement that the materials are "likely to lead to the discovery of other admissible evidence." Motion to Compel at 12 n.3, which is all that plaintiff offers as to Request No. 10. This is particularly so given the reality that parties often take positions or offer potential compromise solutions during plea negotiations which are inconsistent with the litigation strategy they will pursue if the case goes to trial. As one court has explained in the civil context:
+
+There exists a strong public interest in favor of secrecy of matters discussed by parties during settlement negotiations. . . . The ability to negotiate and settle acase without trial fosters amore efficient, more cost-effective, and significantly less burdened judicial system. . . . Parties must be able to abandon their adversarial tendencies to some degree. They must be able to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts.
+
+Goodyear Tire, <sup>332</sup>F.3d at 980. The same is no less true in the plea negotiation context. The free availability in discovery to civil plaintiffs of communications made during the plea negotiation process has profound potential to chill I. and open communications during that process so crucial to the functioning of the criminal justice system in any criminal case which has potential to become acivil or regulatory matter as well. Such defendants will be loath to be fully forthcoming during plea discussions or communications and indeed, if the potential civil or regulatory consequences are sufficiently severe, may decline to enter into plea negotiations at all, if they must fear that their communications will be made available to civil plaintiffs in discovery, thus entirely defeating both the purpose and spirit of Rules 410 and 11(f).
+
+In addition, the communications made during the plea negotiation process contain fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particularly given the strong public policy in favor of confidentiality of plea/settlement negotiations, the disclosure of such information should be treated as falling within the selective waiver provisions of Fed. R. Evid. 502 and not be treated as an open-ended waiver of the attorney-client and work product privileges.
+
+The correspondence in question contained what would constitute paradigm opinion work product with the single caveat that the opinions of each counsel, Epstein's and the United States Attorney's were exchanged with each other pursuant to the overall expectation that they were safeguarded from disclosure by the policies of confidentiality that protect communications during settlement and plea negotiations. The requested communications include the views of
+
+Page No. 8
+
+Epstein's counsel in the criminal case regarding why a federal prosecution was inappropriate, why the federal statutes did not fit the alleged offense conduct, why certain of the alleged victims were not credible. It also includes Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. §2255, one of the principal causes of action in the Jane Doe cases. This opinion work product should not be disclosed when it was incorporated into heartland plea negotiations that are accorded protection under the federal rules of evidence. It is the disclosure of such legal opinions — and not just their admissibility — that should be protected from a civil discovery request that lacked any statement as to why this information was even nereqsary to the fair litigation of the civil cases.
+
+Concomitantly, to the extent that the request is now limited to communications from the Government to Epstein, see DE 54, pgs 3 and 8, the narrowed request implicate the same concerns for the opinions, the work product, and the expectation of privacy of the United States Attorney or Assistant United States Attorney who authored the many letters received by counsel for Epstein. As such, to the extent that the Court is considering affirming any part of the Magistrate-Judge's opinion allowing request 10 that would result in the required disclosure of communications from the Government counsel to Epstein, that notice be provided to the United States Attorney so they may intervene to protect their opinion work product, assert their rights to confidentiality under FRE 408 and 410, and assert where appropriate their interests in grand jury secrecy and in the privacy rights of their witness who in at least one document are identified. The defendant requests that if the Court were considering allowing the disclosure of any portion of the communications sent by Epstein to the Government which are within the original request for production but apparently not plaintiff's latest filing, DE 354, pg 3, the Court first consider
+
+Page No. 9
+
+permitting the defendant to provide a privilege log that would identify specific portions of the correspondence that contains the opinion work product of counsel for Epstein
+
+Here, the information requested involves negotiations with the USAO and its investigation. If the USAO cannot be compelled to release its investigation(s) and related workproduct, how can Epstein be compelled to disclose same in violation of his constitutional rights? He cannot. Rules 11(f), 408, and 410 all counsel strongly against the discoverability of such documents. The court, is requested to reverse the Magistrate-Judge's order as to paragraph 10. Alternatively, the Court is requested to permit a privilege log that would be filed by Epstein's counsel — and if they so desire the Government — particularizing the prejudice to their work product and to the values otherwise protected by FRE 408 and 410 on <sup>a</sup>document by document basis
+
+Epstein also continues to maintain that the requested correspondence is protected under the Fifth Amendment, as it could furnish alink in the chain of evidence needed to prosecute him for acrime or provide the federal government with information that provides alead or clue to evidence having a tendency to incriminate Epstein. See infra; Hoffman v. United States, <sup>341</sup> U.S. at 486; United States v. Neff, <sup>315</sup>F.2d at 1239; Blau v. United States, <sup>340</sup>U.S. at 159; and SEC v Leach, 156 F.Supp.2d at 494.
+
+As this court has recognized, the threat of criminal prosecution is real and present as Epstein remains under the scrutiny of the USAO, which is explained and/or acknowledged in the Court's Orders (DE 242 and 462). As this Court knows, Epstein entered into aNon-Prosecution Agreement ("NPA") with the USAO for the Federal Southern District of Florida. However, the NPA does not provide Epstein with any protection from criminal investigation or prosecution in other than in the Southern District of Florida. As the court has acknowledged in its orders (e.g.,
+
+Page No. 10
+
+DE 462), complaints in these related matters allege that Epstein both resided in and allegedly engaged in illegal sexual conduct in districts outside the Southern District of Florida, and that he allegedly lured economically disadvantaged girls to homes other than in Palm Beach. Thus, the fact that there exists a NPA does not mean that Epstein is free from a reasonable fear of future criminal prosecution. In fact, this court acknowledged that "[t]he danger Epstein faces by being forced to testify in this case is substantial and real, and not merely trifling or imaginary as required." (DE 242, p. 10).
+
+As such, in the event Epstein is required to produce information provided to him by the federal government — or provided by Epstein to the Government - that information could provide a link in the chain of evidence needed to prosecute Epstein of a crime outside the protections of the NPA. Given the nature of the allegations, to wit, a scheme and plan of sexual misconduct, this court should find it entirely reasonable for Epstein to assert his Fifth Amendment privilege as to request Number 10, especially since it is broad enough to encompass information that could violate Epstein's Fifth Amendment Privileges. Hubbell, supra. In responding to the request, Epstein would be compelled admit that such documents exist, admit that the documents were in his possession or control, and were authentic. In other words, the very act of production of the category of documents requested would implicitly communicate "statements of fact." Hubbell,supra; Hoffman,supra.
+
+Moreover, the production of such information may lead to the identity of witnesses that could testify against Epstein and those that may have knowledge or are in possession of evidence that could be used against Epstein in another district. This court has already ruled that Epstein can properly invoke his Fifth Amendment right to nat identify a person who may have a photograph
+
+Page No. I I
+
+or physical evidence pertaining to the alleged events. (DE 242). For these reasons, Epstein's justified concern with regard to answering the above request and the resulting waiver of his Fifth Amendment Privilege in this regard and/or providing self-incriminating information is substantial, real and not merely imaginative.
+
+# Third Party Privacy Rights And Judge Jeffrey's Colbath's Order
+
+The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows full well, attached to the NPA is alist which delineates alleged victims. Once the NM was made public, Judge Colbath, with the agreement of the Palm Beach Post, Brad Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private. As such, Request for Production Number 10 seeks information that may violate others third-party privacy rights in that certain names may be mentioned in correspondence, including those on the "list." As noted in Eisenstadt v. Baird, <sup>405</sup>U.S. 438, 454, 92 S.Ct. 1029, 1038, at fn. 10 (1972):
+
+In Stanley, <sup>394</sup>U.S., at 564, 89 S.Ct., at 1247, the Court stated:`(A)Iso fundamental is the right to be free, except in very limited circumstances, from unwanted governmental intrusions into one's privacy." The makers of our Constitution undertook to secure conditions favorable to the pursuit of happiness. They recognized the significance of man's spiritual nature, of his feelings and of his intellect. They knew that only a part of the pain, pleasure and satisfactions of life are to be found in material things. They sought to protect Americans in their beliefs, their thoughts, their emotions, and their sensations. They conferred, as against the Government, the right to be let alone-the most comprehensive of rights and the right most valued by civilized man.' [Citations omitted].
+
+The fundamental right of privacy is not only guaranteed under by the Fourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, <sup>553</sup> So.2d 148, 150-51 (Fla. 1989):
+
+The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited observation of or interference in those aspects of their lives which fall within the ambit of this zone of privacy unless the intrusion is
+
+Page No. 12
+
+warranted by the necessity of a compelling state interest. In an opinion which predated the adoption of section 23, the First District aptly characterized the nature of this right.
+
+<sup>A</sup>fundamental aspect of personhood's integrity is the power to control what we shall reveal about our intimate selves, to whom, and for what purpose.
+
+Bryon, Harless, Schaffer, Reid & Assocs., Inc. v. State ex rel, Schellenberz <sup>360</sup> So.2d 83, 92 (Fla. 1st DCA 1978), quashed and remanded on other rounds, <sup>379</sup> So.2d 633 (Fla.1980). Because this power is exercised in varying degrees by differing individuals, the parameters of an individual's privacy can be dictated only by that individual. The central concern is the inviolability of one's own thought, person, and personal action. The inviolability of that right assures its preeminence over "majoritarian sentiment" and thus cannot be universally defined by consensus.
+
+(Emphasis added).
+
+Clearly, the nature of the question would require Epstein to produce information that may identify third parties (including alleged victims), which would necessarily thwart such individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. See generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in one's sexual matters and is not limited to the marital relationship). The Magistrate's Order did not address this issue.
+
+Federal law provides crime victims with rights similar to those afforded by the Florida constitution which includes, but is not limited to, "the right to reasonable, accurate, and timely notice of any pubic court. . .proceeding involving the crime. . . . ," "the right not to be excluded from any public court proceeding. . . . ," and "the right to be heard." 15 Fla. Jur.2d Crim.Proc. §1839; Fla. Stat. 960.0021. Based upon the foregoing, any alleged victim that may be identified in any of the requested information must first be notified, which means that this court must, at the very least, conduct an in camera inspection of any and all information to determine which alleged victim must be placed on notice that their identity may be revealed or redact their names
+
+Page No. 13
+
+in camera. See also Fla. Stat. §794.03, §794.024 and §794.026. The right to privacy encompasses at least two different kinds of interests, the individual interests of disclosing personal matters and the interest in independence in making certain kinds of important decisions. Favalora v. Sidaway, <sup>966</sup>So.2d 895 (Fla. 4th DCA 2008).
+
+Accordingly, based on the facts and circumstances of this case, and under applicable law, Defendant's assertion of the protections afforded under the 5th, 6'h, and 14ih Amendments of the United States Constitution are required to be upheld. In addition, this Court must address the privacy rights of others as outlined above.
+
+### b. Request Number <sup>12</sup>
+
+Request No. 12: Personal tax returns for all years from 2002 through the present.
+
+Response to Request Numbers : Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit without waiving my Fifth Amendment constitutional rights and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad.
+
+As set forth in more detail in DE 282 and 283, which were provided to the court in camera, Epstein cannot provide answers/responses to questions relating to his financial history and condition without waiving his Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution, which includes his tax returns. Asking for Epstein's personal tax returns is financial in nature and it is confidential, proprietary and seeks information much of which is neither relevant to the subject matter of the pending action nor does it appear to be
+
+Page No. 14
+
+reasonably calculated to lead to the discovery of admissible evidence. Importantly, the Magistrate did not make a ruling on relevancy as to the personal tax returns, and the Plaintiff has not met the burden of establishing a "compelling need" for the tax returns.
+
+Producing the specified information, in full, would result in testimonial disclosures that would communicate statements of fact and would require Epstein to produce the returns and thereby "stipulate" to their genuiness, their existence, his control of the records, and their authenticity as his executed tax returns even though his possession of such records are by no means <sup>a</sup>foregone conclusion. Again, the information sought relates to potential federal claims of violations. See DE 282 and 283, in camera. Production would therefore constitute <sup>a</sup> testimonial admission of the genuineness, the existence, and Epstein's control of such records, and thus presents areal and substantial danger of self-incrimination in this case, in other related cases and as well in areas that could result in criminal prosecution. See generally Hoffman <sup>v</sup> United States <sup>341</sup>U.S. at 486; United States v. Hubbell, <sup>530</sup>U.S. at 36 and United States v. Apfelbaum, <sup>445</sup>U.S. at 128.
+
+The Court's order seems to hone in on the "required records" exception for the proposition that, as a matter of law, Epstein's personal tax returns must be produced because they are allegedly a mandatory part of acivil regulatory scheme and have assumed some public aspect. (DE 462, p.12) However, "required records" are ordinarily records collected by highly regulated business (e.g., physicians) wherein the records themselves have assumed public aspects which render them analogous to public documents. See In re Dr. John Doe, <sup>97</sup>F.R.D. 640, 641- <sup>643</sup>(S.D.N.Y. 1982). Usually, these documents are known to more than the filer and the agency in which the document(s) were filed (i.e., known to other persons of the general public). Id. Even though the IRS may have certain returns, they remain confidential under 26 U.S.C. §6103
+
+from any disclosures and are therefore different than a regulated/public record that can be accessed by the public. In Trudeau v. New York State Consumer Protection Bd., <sup>237</sup>F.R.D. <sup>325</sup> (N.D.N.Y. 2006), the court maintained that "[r]outine discovery of tax returns is not the rule but rather the exception." Id. at 331. The Court went on to note that [f]or nearly the pas<sup>t</sup>thirty-five years, tax returns have been considered `confidential,' pursuant to 26 U.S.C. §6103." Id. Because of the principle of confidentiality, it further noted, "courts in the Second Circuit have found personal financial information to be presumptively confidential or cloaked with a qualified immunity," and must, therefore, "balance the countervailing policies of liberal discovery set forth in the Federal Rules of Civil procedure against maintaining the confidentiality of such documents." Id.
+
+To achieve that balance, courts in the Second Circuit have developed a"more stringent" standard than that set forth in the rules. To order disclosure of tax returns, acourt must find that "the requested tax information is relevant to the subject matter of the action" and that "there is <sup>a</sup> compelling need for this information because the information contained therein is not otherwise readily available." Id. The Magistrate's Order makes no such finding in the instant matter. In fact, the burden of showing compelling need is on the party seeking discovery, but once <sup>a</sup> compelling need has been found, the party whose tax return information has been requested has the burden to "provide alternative sources for this sensitive information. Id. If the requested information is available from alternate sources, disclosure should not be compelled. Potential alternate sources to which the court pointed were gathering the information through deposition or disclosure in an affidavit by the requested party of net worth, wealth, and income. Id. at 331-32. ,wee Barton v. Cascade Regional Blood Services, <sup>2007</sup>WL 2288035 (W.D.Wash. 2007)("Tax returns are confidential communications between the taxpayer and the governmen<sup>t</sup>[citing
+
+§6103] and although not privileged from discovery there is a recognized policy against unnecessary public disclosure The Court finds no compelling need which overcomes this recognized policy"). Courts have broadly construed these provisions to embody a genera<sup>l</sup> federal policy against indiscriminate disclosure of tax returns from any source. Federal Say. & Loan Ins. Corp. v. Krueger, <sup>55</sup>F.R.D. 514-15 (N.D. III. 1972)("it is the opinion of this court that [§6I03] reflect[s] avalid public policy against disclosure of income tax returns. This policy is grounded in the interest of the government in full disclosure of all the taxpayer's income which thereby maximizes revenue. To indiscriminately compel ataxpayer to disclose this information merely because he has become a party to alawsuit would undermine this policy"); see also Premium Service Corp. v. Sperry & Hutchinson Co., <sup>511</sup>F.2d 225, 229 (9th Cir. 1975)(would have been appropriate for district court to quash subpoena for tax returns based on the "primacy" of the "public policy against unnecessary disclosure [of tax returns] arises from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns").
+
+In Pendlebury v. Starbucks Coffee Co., <sup>2005</sup>WL 2105024 at \*2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and that courts should be reluctant to order disclosure during discovery. Citing, Natural Gas Pipeline Co. of Am. v. Energy Gathering, Inc., <sup>2</sup>F.3d 1397, 1411 (5'<sup>h</sup> Cir. 1993); DeMasi v. Weiss, Inc., <sup>669</sup>F.2d 114, 119-20 (3d Cir. 1982)(noting existence of public policy against disclosure of tax returns); Premium Serv. Corp. v. Sperry & Hutchinson Co., <sup>511</sup>F.2d 225, 229 (91h Cir. 1975). The court in Pendlebury agreed that parties seeking the production of tax returns must demonstrate (1) relevance of the tax returns to the subject matter of the dispute and (2) a compelling need for the tax returns exists because the information contained therein is not otherwise available. Id. at \*2; see also Dunkin Donuts, Inc. v. Mary's Donuts, Inc., <sup>2001</sup>WL 34079319 (S.D. Fla. 2001);
+
+MB v. Hallaarten & Co., <sup>34</sup>F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the Plaintiff must satisfy the "relevance" and "compelling need" standards. The Magistrate's Order fails to address the "relevancy" standard and Plaintiff fails to provide same with supporting argument and case law, and the Plaintiff fails to delineate any "compelling need" or availability of networth from other sources (e.g., a stipulation as to net worth, which is certainly an alternative means). To the extent that the Court determines that the tax returns are relevant and that there is a compelling need for at least their disclosure of Epstein's wealth for punitive damage purposes, Epstein would agree to stipulate, through his attorneys, that he has anet worth of over \$50,000,000. Such a stipulation more than satisfies any necessity for the disclosure of the tax returns or any additional net worth information.
+
+This court already ruled in DE 462 that Epstein is not required to produce his financial history information to the extent same seeks to identify Epstein's assets, where such assets are located and whether such assets have been transferred. Id. Moreover, the names and addresses of his accounts, financial planners and money managers were also sustained pursuant to the Fifth Amendment. Id. Therefore, to the extent this court orders production of tax returns and to the extent Epstein's personal tax returns contain such information, same should be redacted and subject to heightened confidentiality. However, this can only be done subsequent to an in camera hearing wherein this court can make a ruling on relevancy, production, redaction and confidentiality; but only after the Plaintiff shows a compelling need.
+
+Furthermore, Epstein's complicated business transactions have no relevancy to this lawsuit and, therefore, evidence of same should not be produced. The Fifth Amendment is asafe harbor for all citizens, including those who are innocent of any underlying offense. This request,
+
+if answered, may result in compelled production and/or testimonial communications from Epstein regarding his financial status and history and would require him to waive his right to decline to respond to other inquiries related to the same subject matter. Responding to this and other related inquiries would have the potential to provide alink in achain of information and/or leads to other evidence or witnesses that would have the specific risk of furthering an investigation against him and therefore are protected from compulsion by Epstein's constitutional privilege.
+
+Accordingly, any compelled testimony that provides a"lead or clue to a source of evidence of such [a] crime" is protected by Fifth Amendment. SEC v Leach, <sup>156</sup>F.Supp.2d at 494. Questions seeking "testimony" regarding names of witnesses, leads to phone or travel records, or financial records that would provide leads to tax or money laundering or unlicensed money transmittal investigations are protected. See also Hoffman vUnited States, <sup>341</sup>U.S. 479, <sup>486</sup>(1951)("the right against self-incrimination may be invoked if the answer would furnish <sup>a</sup> link in the chain of evidence needed to prosecute for a crime").
+
+## c. Request Number <sup>13</sup>
+
+Request No. 13: <sup>A</sup>photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements.
+
+Response: Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit without risking waiver of my Fifth Amendment rights and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional protections
+
+> and privileges, the scope of information is so overbroad that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence; compiling such information over <sup>a</sup>six year period would be unduly burdensome and time consuming.
+
+As to Request Number 13, Defendant provided this court with sufficient argument at DE <sup>282</sup>and DE 283 detailing why the production of information showing Epstein's whereabouts could provide alink in the chain of evidence regarding: (a) Epstein's air travel within the United States and Foreign Territories; (b) Epstein's communications with others relating to or referring to females coming into the United States from other countries; and (c) Epstein's persona<sup>l</sup> calendars and schedules. Given that the essential proof of an allegation of 18 U.S.C. 2423(b) would include travel records, schedules regarding trips and locations, flight records, calendars, and transportation arrangements, the court found that Epstein had made amore particularized showing because producing such information "could reveal the availability to him and/or use by him of interstate facilities and thus would constitute alink in the chain of evidence that could potentially expose [Epstein] to the dangers of self incrimination." (DE 293, p.6) See infra, regarding private aircraft.
+
+The Magistrate's Order (DE 462) provides that Epstein's Fifth Amendment privilege does not extend to his passport because its existence is known to the government or is <sup>a</sup> "foregone conclusion." Id. at p. 11. First, the magistrate's order presupposes that Epstein has all his passports from 2002 up through to the current date and that the government has an exact copy of same. Second, the Order presupposes that U.S. Customs and Border Patrol ("CPB") keeps <sup>a</sup> record and/or has maintained records of Epstein's travel and whereabouts from 2002 up through to the current date. Third, assuming Epstein traveled internationally, the Order presupposes that the CPB has records of all of Epstein's destinations and that other countries have shared that information with the CBP.
+
+For instance, CBP now offers "Global Entry" to enter the United States by kiosk. However, it is unclear whether the Global Entry kiosk records and copies the pages of <sup>a</sup> traveler's destinations outside of the United States, or does it simply record exit from and entry back into the United States?<sup>5</sup> Moreover, it is unclear whether CBP maintains the Sample Customs Declaration Form for any period of time, which form sets out (i.e., if filled out) the countries visited by atraveler.<sup>6</sup> This Court cannot Compel Epstein to produce information in violation of his Fifth Amendment by simply stating that Epstein's passport is "known to the government" or is a "forgone conclusion." In fact, from the websites listed herein, any CBP documents or forms filled out by atraveler take on <sup>a</sup>complete different form when compared to an original passport, which is initially issued with blank pages. This Court would be hardpressed to find that the CBP has an exact copy of every page of every traveler's passport. Obviously, this would create more document management than CBP anticipates on its website.
+
+Moreover, pursuant to 19 C.F.R. §122.2, pilots of private aircraft are required to electronically transmit passenger and crew manifest information for all flights arriving into and/or departing out of the United States. As this court knows, Mr. has conducted extensive discovery, has questioned individuals as to whether Epstein owns private aircraft and has obtained certain flight manifests. Arguably, if such a procedure were followed in Epstein's case pursuant to 19 C.F.R. §122.2, then Epstein's passport would arguably take on <sup>a</sup> substantially different form when compared to the information maintained by the CBP (i.e., information that was electronically transferred). Under that circumstance, CLIP would not have an exact copy of Epstein's passports. Accordingly, the assumptions made in the Magistrate's Order have serious Fifth Amendment implications in that the exact information sought is not
+
+<sup>5</sup> Lc" gsg. <sup>6</sup> htto://www.customs.aov/xo/cgov/travellvacation/sample declaration form.xml htto://www.customs.gov/xo/czov/travel/trusted traveler/aloha' entry/
+
+"known to the government" and is not a "forgone conclusion" in that the government is not likely to have an exact copy of Epstein's passports.
+
+Again, Plaintiff's request for Epstein's passpor<sup>t</sup>"reflecting travel to locations outside the <sup>50</sup>United States between 2002 and 2008, is no different from the requests this Court has already ruled upon and sustained Epstein's Fifth Amendment privilege in response thereto. (DE 292). In summary, this court reasoned that:
+
+"[On this and the other civil actions, Plaintiff's allege that Epstein violated certain federal and state criminal statutes in an attempt to make claims against Epstein ranging from sexual battery to intentional infliction of emotional distress. The lynchpin for the exercise of federal criminal jurisdiction under 18 U.S.C. §2422(b), which figures in some of the complaints filed, is `the use of any facility or means of interstate or foreign commerce' and the analogous essential element of 18 U.S.C. §2423(b), which also figures in some of the Complaints, is `travel[s] in interstate commerce or travels into the United States or . . . travels in foreign commerce.' Accordingly, requiring Epstein to provide responses. . .would in essence be compelling him to provide assertions of fact, thereby admitting that such documents existed and further admitting that the documents in his possession or control were authentic.
+
+As such, if you believe Plaintiff's footnote 4 at (DE 210), responding to this reques<sup>t</sup> could very well implicate Epstein's Fifth Amendment privilege. The allegations of Epstein's use of interstate commerce and travel and any compelled production is clearly aviolation of Epstein's Fifth Amendment rights' Based upon the arguments set forth in DE 283 (which is incorporated herein), this Court sustained Epstein's Fifth Amendment Privilege. That same ruling should apply here. (DE 293). If not, this court may be requiring Epstein to produce a log of his travels, which this Court already sustained under the Fifth Amendment.
+
+Plaintiff must also show that the requested information is relevant to the disputed issues of the underlying action. See Young Circle Garage. LLC. v. Konnel, <sup>916</sup>So. 2d 22 (Fla. 4th DCA
+
+Once again, a ruling on these issues cannot be made in a vacuum. This court must, as it has done in the past, consider the other related cases and the allegations made therein when considering whether a response to a particular discovery requests would implicate Epstein's Fifth Amendment rights. leg DEs 242, 283 and 462.
+
+2005); see also Equitable Life Assurance Society of the United States v. Daisy Worldwide, Inc., <sup>702</sup>So. 2d 263 (Ha. 3d DCA 1997). Plaintiff has failed to meet this burden and, in doing so, has also failed to show any substantial need for the documents.
+
+Wherefore, Epstein respectfully requests that this Court issue and order:
+
+- a. finding that the danger Epstein faces by being forced to testify in this case relative to the above requests is substantial and real, and not merely trifling or imaginary;
+- b. sustaining Epstein's Fifth Amendment Privilege as it relates to the above requests and denying Plaintiff's Motion in that regard;
+- c. reversing and/or revising the Magistrate's Order (DE 462) relative to Request Numbers 10, 12 and 13 and entering an amended order sustaining Epstein's objections to the Magistrate's Order as to those specific requests and not requiring him to produce information relative to same; and/or
+- d. remanding this appeal to the Magistrate-Judge for her reconsideration of these portions of her order;
+- e. alternatively, if this court rules that any of the information requested herein is relavent, it shall only do so after an in camera hearing and only after this court ensures that each and every documents produced is the subject of a heightenedconfidentality order;
+  - f. for such other and further relief as this Court deems just and proper.
+
+Respectfully ted,
+
+E, ESQ. 296
+
+#### Certificate of tiers ice
+
+<sup>I</sup>HEREBY CERTIFY that atrue 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 by CM/ECF on this 26th day of February, 2010.
+
+Respectfully <sup>s</sup>
+
+By:
+
+ROB TTON, JR., ESQ.
+
+Florida Bar N . 224162
+
+rcri cla
+
+MICHAEL J. PIKE, ESQ.
+
+Florida Bar #617296
+
+mnike@bc1claw.com
+
+BURMAN, CRITTON, LUTTIER & COLEMAN
+
+515 N. Flagler Drive, Suite <sup>400</sup>
+
+West Palm Beach, FL 33401
+
+561/842-2820 Phone
+
+561/515-3148 Fax
+
+(Counsel for Defendant Jeffrey Epstein)
+
+### Certificate of Service
+
+Jane Doe No. 2 v. Jeffrey E •
+
+Case No. 08-CV-80119-MA
+
+Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mennelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ssmalsexabuseattorney.com
+
+, Jaffe, Weissing, Fistos & Lehrman, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 brad(apathtqiustice.com Counsel for Plaintiff in Related Case No. 08-
+
+ahorowitz@sexabuseattornev.com
+
+Counsel for Plaintiffs In related Cases Nos. 0840069, 08-80119, 08- 80232, 08-80380, 08-80381, 08-80993, 08- 80994
+
+Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 iaaesa@bellsouth.net
+
+Counsel for Defendant Jeffrey Estein
+
+80893
+
+Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax casselligalaw.utah.edu
+
+Co-counsiiiihilaituiff Jane Doe
+
+Firm, li Law Esq. PA. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F bidroRarciagbellsouth.net Counsel for Plaintiff in Related Case No. 08- 80469
+
+Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. <sup>25</sup>West Flagler Street, Suite <sup>800</sup> Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsberu@podhurst.com kezell®podhurst.com
+
+Counsel for Plaintiffs in Related Case

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marker2/court-doe-v-epstein-80119/EFTA02748708/EFTA02748708.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-cv-80119-MARRA/.
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related cases:
+
+08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+## DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOES 2-8'S NOTIFICATION OF 90 DAYS EXPIRING ON MOTION TO COMPEL (DE 474)
+
+Defendant, Jeffrey Epstein, by and through undersigned counsel hereby files his Response to Plaintiffs Jane Does 2-8's Notification of 90 Days Expiring, and states as follows:
+
+1. On July 20, 2009, Plaintiff Jane Doe (#08-80893) filed Motions to Compel Responses to Request for Production (DE 210), Answers to Requests for Admission (DE 211), and Answers Interrogatories (DE 212). Many of the Requests in PlaintiffJane Doe's (08-80893) Motions to Compel address similar requests in Jane Does 2-8's Motion to Compel Responses and Requests for Net Worth Discovery (DE 333).
+
+2. On October 6, 2009, Defendant Jeffrey Epstein, filed his Responses and Objections to Plaintiff Jane Doe's (08-80893) Motions to Compel (DE 340, 341, and 342).
+
+- 3. On November 2, 2009, Defendant Epstein, filed his Response in Opposition to Plaintiffs Jane Does 2-8's Motion to Compel (DE 390).
+- 4. On February 4, 2010, this Court entered an Omnibus Order on similar financial net worth discovery (DE 462).
+- 5. As such, what Defendant contends is the Omnibus Order entered on February 4, 2010 (DE 462) applies (in part or in whole) to Jane Does 2-8's Motion to Compel Net Worth Discovery, noting however, Defendant has appealed portions of the same Omnibus Order on February 26, 2010 (DE 477).
+
+By: /s/ Michael J. Pike ROBERT D. CRITTON, JR., ESQ. Florida Bar #224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296
+
+## Certificate of Service
+
+<sup>I</sup>HEREBY CERTIFY that atrue copy of the foregoing was being served this day on all counsel of record identified on the following Service List via electronic mail (EMAIL) on this 3nd day of March, 2010.
+
+Respectfully submitted,
+
+By: /s/ Michael J. Pike ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 rcrit@bciclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpike@bciclaw.com
+
+BURMAN, CRITTON, LUTITIER & COLEMAN <sup>303</sup>Banyan Blvd., Suite <sup>400</sup> West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax (Counsel.\* Defendant Jeffrey Epstein)
+
+## Certificate of Service Jane Doe No. 2 v. Jeffrey E ' Case No. 08-CV-80119-MARRAr
+
+Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ssm@sexabuseattomev.com ahorowitz@sexabuseattomey.com Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 iagesq®bellsouth.net Counsel for Defendant Jeffrey Epstein Robert C. Josefsberg, Esq.
+
+Katherine W. Ezell, Esq. Podhurst Orseck, P.A.
+
+<sup>25</sup>West Flagler Street, Suite <sup>800</sup>
+
+Miami, FL 33130 305 358-2800 Fax: 305 358-2382
+
+Est Jaffe, Weissing, , Fistos & Lehrman, PL 425 N. Andrews Ave. Suite #2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 Brad@oathtoiustice.com Counsellor Plaintiff in Related Case No. 08-80893
+
+Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax casseilo@taw.utah.edu Co-counsel for PlaintiVane Doe
+
+Escl• mg. Law Finn, P.A. 224 Datum Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidroscarcia@bellsouth.net Counsel for Plaintiff in Related Case No. 08-80469
+
+rjosefsberg@podhurst.com kezell@podhurst.com

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marker2/court-doe-v-epstein-80119/EFTA02748712/EFTA02748712.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO: 08-80119-CIV-MARRA
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## Related cases:
+
+08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+## ORDER
+
+THIS CAUSE is before the Court on Third Party Witness, Motion for Protective Order (D.E. #475). Having reviewed the Motion filed by the non-party and being otherwise duly advised in the premises, it is hereby
+
+ORDERED AND ADJUDGED that Third Party Witness, Motion for Protective Order (D.E. #475) is GRANTED nunc pro tunc.. By this Motion the non-party referred to above seeks an order allowing her deposition to be rescheduled from March 1, 2010, to another date agreed upon by all interested parties due to a scheduling conflict of her attorney. For "good cause" shown the Court may issue a protective order preventing or delaying a deposition. Fed. R. Civ. P. 26(c); see McCarthy v. Barnett Bank of Poly County, 876 F.2d 89, 91 (11th Cir. 1989). Finding good cause present in this instance, the
+
+Court orders the subject deposition be re-scheduled for a date and time mutually agreeable
+
+to all concerned.
+
+**DONE AND ORDERED** this March 3, 2010, in [REDACTED], at West Palm
+
+Beach, Florida.
+
+LINNEA R. JOHNSON  
+UNITED STATES MAGISTRATE JUDGE
+
+![]()CC: The Honorable Kenneth A. Marra  
+All Counsel of Record

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marker2/court-doe-v-epstein-80119/EFTA02748714/EFTA02748714.md

@@ -0,0 +1,73 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 08-CIV-80119-MARRA
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related cases:
+
+08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+## ORDER
+
+THIS CAUSE is before the Court on Plaintiffs' Motion to Compel Responses to Net Worth Discovery (D.E. #333). For the following reasons said Motion is granted in part and denied in part as follows.
+
+In this case, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls in question were approximately 16 years of age. As part of this scheme, Epstein, with the help of his assistant allegedly lured economically disadvantaged minor girls to his homes in Palm beach, New York and St. with the promise of money in exchange for a massage. Epstein purportedly transformed the massage into a sexual assault. The three-count Complaint alleges sexual assault and battery (Count I), intentional infliction of emotional distress (Count II), and, coercion and enticement to sexual activity in violation of 18 U.S.C. §2422 (Count III).
+
+In 2008, Epstein entered into a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms and conditions contained therein. If at any time the United States Attorney's Office has reason to believe Epstein is in breach of the Agreement, it need only provide Epstein's counsel with notice of the breach and then move forward with Epstein's prosecution. Accordingly, the mere fact the Government and Epstein have entered into a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution.
+
+By the instant Motion Plaintiffs seek an order compelling Epstein to respond to various discovery requests (production and interrogatory) which seek information related to Epstein's net worth. Defendant has responded by asserting several objections, which to the extent necessary shall be discussed subsequently herein, the primary one of which is an assertion of his Fifth Amendment privilege.
+
+The Fifth Amendment serves as a guarantee against testimonial compulsion and provides, in relevant part, that lily:, person...shall be compelled in any Criminal Case to be a witness against himself." Id. In practice, the Fifth Amendment's privilege against selfincrimination "permits a person not to answer official questions put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded "liberal construction in favor of the right it was intended to secure," Hoffman v. United States, 341 U.S. 479, 486 (1951), and extends not only to answers that would in themselves support a criminal conviction, but extends also to those answers which would furnish a link in the chain of evidence needed to prosecute the claimant for a crime. Id.; Blau v. United States, 340 U.S. 159 (1950). Thus, information is protected by the privilege not only if it would support a criminal conviction, but also in those instances where "the responses would merely 'provide a lead or clue' to evidence having a tendency to incriminate." United States v. Neff, 615 F.2d 1235, 1239 (9th Cir.), cert. denied, 447 U.S. 925 (1980).
+
+The Fifth Amendment's privilege against self-incrimination comes into play only in those instances where the witness has "reasonable cause to apprehend danger from a direct answer." Hoffman, 341 U.S. at 486 (citing Mason v. United States, 244 U.S. 362, 365 (1917)). "The claimant must be 'confronted by substantial and 'real,' and not merely trifling or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980).
+
+When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead, the privilege must be asserted in response to a particular question, and in each instance the burden is on the claimant to justify invocation of the privilege. Id. Once a particularized showing has been made, "[i]t is for the court to decide whether a witness' silence is justified and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making this determination the judge is instructed to view the facts and evidence presented on a caseby-case basis, and "must be governed as much by his perception of the peculiarities of the case, as by the facts actually in evidence." Hoffman, 341 U.S. at 487.
+
+The law is well established that the Fifth Amendment privilege may not apply to specific documents "even though they contain incriminating assertions of fact or belief, because the creation of those documents was not 'compelled' within the meaning of the privilege." United States v. Hubbell, 530 U.S. 27, 35-36 (2000). However, in certain instances, "'the act of production' itself may implicitly communicate 'statements of fact.'" Id. For this reason the Fifth Amendment privilege also encompasses the circumstance where the act of producing documents in response to a subpoena or production request has a compelled testimonial aspect Id. Thus, in those instances where the existence and/or location of the requested documents are unknown, or where production would "implicitly authenticate" the requested documents, the act of producing responsive documents is considered testimonial and is protected by the Fifth Amendment. In re Grand Jury Subpoena, 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976)(issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's authenticity, existence or possession by the defendant).
+
+The Court begins with an analysis of the Fifth Amendment privilege as applied to each request or category of requests. In the event the Court determines that a certain request does not infringe upon Epstein's Fifth Amendment privilege, Epstein's additional objections to that request shall be addressed. Where appropriate, the Court looks to those portions of Defendant's Response Memorandum submitted in camera. In this regard, the Court notes that in their Reply Memorandum (D.E. #426), Plaintiffs take issue with Defendant's failure to obtain court approval before submitting the subject material for in camera review. While the Court agrees the better practice would have been to obtain court approval before such filing, under the unique circumstances of this case, the undersigned does not find such lapse fatal to Defendant's position. For purposes of completeness, however, the undersigned hereby sua sponte allows the in camera submission provided by Defendant, which the undersigned has this day submitted for filing under seal in the Clerk's Office.
+
+The requests at issue are in the form of interrogatories and requests for production and essentially seek overlapping information, namely, all federal and state income tax returns and related documents filed with the government between 2003 and 2008 (Prod. Reqst. No. 1 and Interr. Reqst. Nos. 2 - 3); all documents relating to Defendant's assets, liabilities, income, expenses and net worth for the last five years (Prod. Reqst. No. 2 and Interr. Reqst. Nos 1-7, 10-12); all documentation relating to financing or loans requested or applied for by the Defendant including loan applications, appraisals, financial spreadsheets, etc. (Prod. Reqst. No. 3 and Interr. Reqst. Nos. 1-3, 7); all appraisals indicating fair market value of real estate and other property owned by Defendant (Prod. Reqst. No. 4 and Interr. Reqst. Nos. 8-9 ); and, all documents relating to any investment or savings accounts owned or controlled by Defendant such as account statements and summaries (Prod. Reqst. No. 5 and Interr. Reqst. Nos. 1-2, 10-12). As stated previously Defendant raised the same general objection to each of these requests, the primary objection being that to force him to respond would violate his Fifth Amendment privilege against self-incrimination.
+
+With the exception of Prod. Reqst. No. 1, which shall be discussed subsequently, the Court finds the subject requests objectionable in that they seek compelled statements/admissions that could reasonably furnish a link in the chain of evidence needed to prosecute Epstein in future criminal proceedings related both to the issues in the instant case and/or to the issues that relate to a separate criminal action about which Defendant has a substantial and reasonable basis to be concemed about. In the latter regard the Court relies, in part, upon the submission provided by Defendant in camera with respect to the "target offenses" referenced therein.
+
+As noted previously, the Fifth Amendment privilege against self incrimination is accorded "liberal construction," Hoffman, 341 U.S. at 486, and extends not only to answers that would in themselves support a criminal conviction, but extends also to those answers which would furnish a link in the chain of evidence needed to prosecute the claimant for a crime. Id. Thus to be afforded protection, the answer need not necessarily be enough to support a criminal conviction; it is enough if the response merely provides a lead or clue to evidence having a tendency to incriminate. Neff, 615 F.2d at 1239.
+
+In asserting his Fifth Amendment privilege, Epstein expresses a concern that if forced to respond to the subject requests regarding his financial net worth, financial history and witnesses with knowledge of his actions, he may be deemed to have waived his right to decline to respond to other inquiries related to the same subject matter in this case, the related cases and those matters outlined in Epstein's in camera submission. Given the allegations raised in the various Complaints and the elements required to convict Epstein of a crime, and considering the background facts underlying the instant case, and the issues outlined in Defendant's submission in camera, the Court finds these concerns are reasonable, real and not unjustified. It goes without saying that being forced to produce documents and/or produce lists identifying the existence of the detailed financial information sought and disclosing information regarding the identity and location of
+
+potential witnesses against Defendant is tantamount to forcing testimonial disclosures that would communicate statements of fact. See Fisher, 425 U.S. at 410 (noting that the Fifth Amendment covers situations where the act of producing documents has "communicative aspects of its own wholly aside from contents of the papers produced").
+
+Apart from Defendant's justified concerns regarding waiver, are the very real concerns that by forcing Defendant to respond to the subject discovery requests regarding his financial status and history, the Court risks providing the government with a link in the chain of evidence needed to convict Defendant of a crime. The potential for providing such a "link" is high when one considers that by forcing Defendant to respond, he will be implicitly communicating statements of fact, authenticating documents and testifying to their location, as well as providing clues as to the identity and location of witnesses that by such disclosure may serve to further a criminal investigation against him. Further, as the requests at issue would require disclosure in connection with Defendant's ownership of assets and transfers of assets inside and outside the United States, such disclosure could reveal the availability to him and/or use by him of interstate facilities, which again may implicate Defendant in additional crimes. In short, the requests at issue seek to have Defendant be a witness against himself, assist with Plaintiffs' investigation and identify areas that could result in future prosecution of Defendant, a result clearly prohibited by the Constitution. In this regard, Plaintiffs' claims that Defendant's constitutional rights are "not even remotely implicated" because the requests relate solely to Defendant's net worth and are "unrelated to Defendant's inducement of minors to sexual activity,"' ring hollow. See Rudy-Glanzer v. Glanzer, 232 F.3d at 1263 (the "privilege" against self-incrimination does
+
+<sup>&#</sup>x27; See Plaintiffs' Mtn. (D.E. #333), p.7.
+
+not depend upon the likelihood, but upon the possibility of prosecution and also covers those circumstances where the disclosures would not be directly incriminating, but could provide an indirect link to incriminating evidence).
+
+In accordance with the foregoing the Court finds that such forced disclosure with regard to the requests at issue presents a real and substantial danger of self-incrimination in this case, in other related cases, and relative to other potential realistically based federal claims. The Court finds further that the danger Defendant faces by being forced to testify in this instance is "substantial and real, and not merely trifling or imaginary" as required. Apfelbaum, 445 U.S. 128. On this basis the Court finds the privilege raised as to all requests other than Prod. Reqst. No. 1, which shall be discussed shortly, validly asserted. Accordingly, Defendant's objection as it relates to each of the subject net worth discovery requests, other than Prod. Reqst. No. 1, is sustained and Defendant need not produce documents or serve answers to said discovery requests.
+
+The Court does not hold similarly with respect to Prod. Reqst. No. 1, which seeks "all federal and State income tax returns, including all W-2 forms, 1099 forms and schedules, for tax years 2003-2008," The law is well established that the Fifth Amendment privilege against self-incrimination does not extend to documents whose existence is known to the government or is a foregone conclusion. Fisher, 425 U.S. at 410; United States v. Hubbell, 530 U.S. 27, 44 (2000); United States v. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006). Thus, while the Fifth Amendment covers situations where the act of producing documents has "communicative aspects of its own wholly aside from contents of the papers produced" Fisher, 425 U.S. at 410, the doctrine does not apply where the government has "prior knowledge of either the existence or the whereabouts of the...documents ultimately produced... ." Hubbell, 530 U.S. at 44.
+
+Prod. Reqst. No. 1 seeks production of documents the government is already in possession of, making the government's prior knowledge of the documents sought an obvious and undeniable "foregone conclusion." As such, Defendant can not reasonably and in good faith argue that in producing these documents to Plaintiff he will somehow be incriminating himself. In re Grand Jury Subpoena, 383 F.3d 905,910 (9th Cir. 2004) (noting there can be no self-incrimination by production where the "existence and location of the documents ... are a 'foregone conclusion' and [the claimant] ... adds little or nothing to the sum total of the Government's information by conceding that he in fact has the documents.").
+
+Defendant's alternative objection that tax returns enjoy a higher degree of protection than ordinary financial documents because tax returns are "confidential under federal law,"= does little to advance his cause. The Court has already addressed and rejected this argument finding that where, as here, the moving party has demonstrated a need for the tax returns at issue, the court's order requiring such disclosure voids the confidentiality concerns the law was designed to protect. Notwithstanding the foregoing, in order to ameliorate Defendant's concerns in this regard the undersigned hereby orders that the tax returns and related documents filed with the government that are subject to production by virtue of the within Order may be disclosed only to the parties and to the attorneys of record in this case and to the agents of such parties and/or attorneys and may only be utilized for purposes of this litigation. In accordance with the above and foregoing, it is hereby,
+
+ORDERED AND ADJUDGED that Plaintiffs' Motion to Compel Responses to Net
+
+<sup>=</sup> See Defendant's Resp., p.13.
+
+Worth Discovery (D.E. #333) is GRANTED IN PART AND DENIED IN PART IN ACCORDANCE WITH THE TERMS OF THIS ORDER. For the reasons stated herein, the Court finds Defendant's Fifth Amendment objections validly asserted with respect to each of the subject requests other than Prod. Reqst. No. 1. As for Prod. Reqst. No. 1, Defendant is ordered to produce the documents responsive to this request within ten (10) days from the date hereof, or if said documents are not in Defendant's possession or immediate control, must produce a release with regard to same within five (5) days from the date hereof.
+
+DONE AND ORDERED in , in West Palm Beach Florida, this 4th day of March, 2010.
+
+LINNEA R. JO N N UNITED STAT MAGISTRATE JUDGE
+
+CC: The Hon. Kenneth A. Marra All Counsel of Record

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marker2/court-doe-v-epstein-80119/EFTA02748724/EFTA02748724.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CIV-80119-MARRAJ
+
+JANE DOE NO. 2,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+Related cases:
+
+08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+![](_page_0_Picture_9.jpeg)
+
+## JOINT AGREED ORDER ON DEFENDANT EPSTEIN'S MOTION FOR ORDER FOR THE PRESERVATION OF EVIDENCE
+
+This matter came before the Court on Defendant JEFFREY EPSTEIN's Motion for Order for the Preservation of Evidence, & Incorporated Memorandum A(Pe 4° ) of Law ("Motion to Preserve Evidence"), dated November 12, 2009. The Court having reviewed the file including Rothstein Rosenfeldt Adler, P.A.'s November 16, 2009 Response to Defendant's Emergency Motion for Order for the Preservation of Evidence, the Court enters this Order:
+
+Defendant Epstein's November 12, 2009 Motion to Preserve Evidence [DE # 4053 alleges that Plaintiff's counsel, Rothstein Rosenfeldt Adler, P.A. ("RRA") has been accused of serious unethical and possible criminal misconduct and requests an order requiring the preservation of certain documents identified in Composite Exhibit A to his Motion to Preserve Evidence. On November 13,
+
+Jane Doe No.2 v. Epstein
+
+Case No. 08-CIV4101189
+
+Order on Epstein's Emergency Motion for Order for the Preservation of Evidence
+
+Page 2 of 3
+
+2009, the Court entered its Order on Epstein's Motion to Preserve Evidence on a temporary basis expiring on November 17, 2009. [DE #408]. In a November 16, 2009 Response to Defendant's Emergency Motion for Order for the Preservation of Evidence, Mr. Stettin, in his capacity as RRA's Receiver and Chief Restructuring Officer,' represented that he "understands fully the gravity of document and evidence preservation" and that he Intends to continue to fully comply with his fiduciary duties both as Receiver and now as CRO of an alleged bankruptcy debtor." RRA's Response at 2; [DE # 409]. On November 18, 2009, the Court entered its Order renewing and continuing in effect its November 13, 2009 Order "until such time as [a] proposed order [on the Motion to Preserve Evidence] has been issued by the Court." [DE # 414].
+
+In the meantime, on November 10, 2009, RRA had been put into an involuntary Chapter 11 bankruptcy in the United States District Court for the Southern District of Florida. RRA's Chapter 11 bankruptcy case is still pending as In m: Rothstein Rosenfeldt Adler, P.A., Case No. 09-34791-RBR. On November 20, 2009, after having filed the Response in his capacity as the state court appointed Receiver, Mr. Stettin was appointed RRA's Chapter 11 Trustee. See, In re: Rothstein Rosenfeld( Adler, P.A., Case No. 09-34791-RBR, DE #35.
+
+The duties of a bankruptcy trustee are provided by statute, including that the trustee "be accountable for all property received." 11 U.S.C. § 1106(a); 11 U.S.C. § 704(a)(2). Therefore, a bankruptcy trustee is "charged with the duty of
+
+On November 4, 2009, Mr. Stettin was appointed as RRA's receiver by Judge Jeffrey Streitfeld of the Florida Seventeenth Judicial Circuit in Case No. 09.059301. (DE if 409].
+
+Jane Doe No.2 v. Epstein
+
+Case No. 08-CIV-801189
+
+Order on Epstein's Emergency Motion for Order for the Preservation of Evidence
+
+Page 3 of 3
+
+collecting and reducing the property of the estate and is to be accountable for all such property." Ohio v. Kovacs, 469 U.S. 274, 284,105 S.Ct. 705, 710 (1985). Since the federal bankruptcy code already requires a trustee to assemble and protect a bankrupt's property, therefore essentially covering the relief requested in the Motion to Preserve Evidence, there is no need for the Court to enter a further order as to Mr. Stettin.
+
+t34/kArek DONE and ORDERED this day of February, 2010.
+
+> Linnea R. Joh United States agistrate Judge
+
+Courtesy copies: All Counsel of Record
+
+Kendall Coffey, Esq. Coffey Burlington Office in the Grove, Penthouse 2699 South Bayshore Drive Miami, FL 33133
+
+James C. Cunningham, Jr. Berger Singerman, 2000 South Biscayne Blvd. Suite 1000 Miami, FL 33131

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marker2/court-doe-v-epstein-80119/EFTA02748727/EFTA02748727.md

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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/
+
+Plaintiff,
+
+Vs.
+
+JEFFREY EPSTEIN, et al.
+
+Defendant.
+
+Related Cases:
+
+08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+
+### PLAINTIFF JANE DOE'S MOTION FOR AN ORDER TO SHOW CAUSE AND FOR AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW
+
+Plaintiff, Jane Doe, respectfully files this motion for entry of an order directed to Jean Luc Brunel and his counsel ordering them to show cause why they should not be held in contempt, for sanctions, and for an order compelling Jean Luc Brunel to appear for a deposition within 20 days. After plaintiff Jane Doe served Brunel with a subpoena for a deposition in this case, his attorney, on his behalf, represented that Brunel would appear for a deposition if Jane Doe would postpone the scheduled deposition date. As an accommodation to him, Jane Doe did postpone the scheduled deposition date, but then Brunel has not appeared as agreed for a deposition. After much communication in an attempt to coordinate Brunel's deposition, Brunel's counsel represented that Brunel was outside of the country, and thus unavailable, when in fact he was inside the country
+
+CASE NO: 08-CV-80119-MARRA'
+
+and easily available for a deposition. Because of these false representations, this Court should direct Brunel and his counsel to show cause why they should not be held in contempt. This Court should also compel Brunel to appear for the deposition that was previously scheduled and that he has avoided only through these false representations. Finally, the Court should sanction the appropriate person(s) for causing the undersigned to spend unnecessary time filing this motion.
+
+## BACKGROUND
+
+Jane Doe personally served Jean Luc Brunel in New York City to appear for deposition in this case. The subpoena indicated a deposition date of September 22, 2009 at 10:00 A.M. in New York City, New York. Brunel is an important witness in this case, as he is a good friend of Epstein's and has information regarding Epstein's pattern and practice of obtaining young girls for sexual purposes, relevant issues not yet admitted by Defendant Epstein.
+
+Shortly after Brunel was served, counsel for Jane Doe was contacted by Tama Beth Kudman, Esq., a licensed attorney in Florida. Kudman stated that she represented Brunel with regard to the subpoena and that she would produce Brunel for deposition in West Palm Beach if Jane Doe would agree not to go forward with the deposition date in New York. Counsel for Jane Doe honored that request, and with Kudman jointly arranged a deposition date for Brunel in West Palm Beach for October.
+
+Shortly before his deposition was to take place, Ms. Kudman contacted counsel for Jane Doe to move that deposition date because of a personal conflict. Once again, counsel for Jane Doe agreed. After several conversations regarding the deposition of
+
+CASE NO: 08-CV-80119-MARRA
+
+Brunel, Kudman asked that counsel for Jane Doe set Brunel for deposition in January of 2010, as that was a time when she could assure his availability.
+
+In January, counsel for Jane Doe again contacted Ms. Kudman to arrange a mutually convenient deposition time. Ms. Kudman stated that Brunel would be in Florida the first week of February and she would work to coordinate his deposition for that time.
+
+The undersigned's office contacted Ms. Kudman's office on several occasions in January to coordinate a February deposition date of Brunel. On January 29, 2010, Ms. Kudman returned the call and left a voicemail apologizing for not returning the call sooner and indicating that she had only been waiting to hear from Mr. Brunel as to his availability, and she invited the undersigned to contact her the following week to set it up. On February 5, 2010, counsel for Jane Doe contacted Ms. Kudman to coordinate Brunel's deposition. During that telephone conversation, Ms. Kudman represented that her client, Mr. Brunel, had previously left the country to go to his home country of France before the New Year. Ms. Kudman further represented that while she believed he was going to return, it turned out that he had no plans to return. Ms. Kudman also stated that if Brunel was in the country, she would make good on her representation that she would produce him. However, she had just spoken to him via a telephone call from him in France. Brunel told Kudman that he was staying there indefinitely with no plans to return. In subsequent telephone conversations, Ms. Kudman continued to represent that Mr. Brunel had been out of the country since sometime prior to the New Year and was not planning to return.
+
+CASE NO: 08-CV-80119-MARRAi
+
+Counsel for Jane Doe responded that this representation seemed quite strange, since Brunel has a significant business in the United States. Kudman replied that it was simply too expensive for him to return and that because of the expense he had no intentions of returning. Counsel for Jane Doe then pointed out that when Brunel was served, Kudman had promised he would be produced for deposition. Kudman replied that because he is in France with no plans to return there was simply nothing she could do. Kudman further advised counsel for Jane Doe that if he wanted to take Brunel's deposition in France, then it would be necessary to obtain a Letters Rogatory and go through the Consulate. After these procedures, Kudman then indicated it would be necessary to take a trip to France for his deposition. Counsel for Jane Doe indicated that he might be willing to go through that process, but that he would like for Kudman to tell him if Brunel happened to return to the United States. Kudman promised that she would.
+
+Remarkably, after all of these representations had been made by Kudman, it turns out that Brunel was actually in the United States during the time when Jane Doe was trying to take his depositon. In fact, on February 16, 2010, counsel for Jane Doe took the deposition of Jeffrey Epstein's house manager, Janusz Banaziak. Mr. Banaziak was asked if he knew Mr. Brunel. In summary, he responded that he knew him as Mr. Epstein's friend. He elaborated that Mr. Brunel had stayed with Epstein at Epstein's Palm Beach home on at least two occasions in 2010. The first 2010 visit was in January, when Mr. Brunel stayed for approximately 3 days. Then Mr. Brunel stayed at Mr. Epstein's home from approximately February 10th or 11th through February 14th,
+
+CASE NO: 08-CV-80119-MARRAi
+
+2010. It was known by Epstein that Brunel was coming to stay at the house in February 2010, as he was picked up at the airport and driven to Epstein's home by Epstein's bodyguard, Igor Zinoview, and after his stay with Epstein, Brunel was driven from Epstein's house to the airport by . See deposition of Janusz Banaziak at page 154-161 and 168-16 attached hereto as Exhibit "A."
+
+## MEMORANDUM OF LAW
+
+As is readily apparent from the foregoing facts, Ms. Kudman has either made false representations about Mr. Brunet's whereabouts or Mr. Brunel has made false representations about his whereabouts that she passed on. In either case, they should be required to show cause why her and/or she should not be held in contempt of court for making false representations. See, e.g., Acton v. Target Corp., 2009 WL 5214419 at \*5 (W.D. Wash. 2009) (entering order to show cause why counsel should not be held in contempt for making false representations). In particular, Mr. Brunel and Ms. Kudman should explain how it came to pass that Mr. Brunel was in Florida at the very time that Jane Doe was attempting to take his deposition while Ms. Kudman was confidently reporting that he was unavailable in France. Given the known facts, Ms. Kudman was either an unwitting messenger who passed along false representations delivered to her by her client Mr. Brunel, or she was a knowing participant in Brunel and/or Epstein's attempt to obstruct discovery; either way a show cause order should be entered and the appropriate person(s) sanctioned and held in contempt.
+
+Mr. Brunel and Ms. Kudman should also be required to provide a full explanation of who precisely is paying the attorney fees for Ms. Kudman's services. Most, if not all,
+
+CASE NO: 08-CV-80119-MARRA
+
+of the witnesses that have been deposed in this and related cases against Epstein have appeared with counsel retained and paid for by Defendant Jeffrey Epstein. In this instance, we know that Mr. Epstein was together with his house guest, Mr. Brunel, at a time when Brunel's counsel was representing that Brunel was out of the country and could thus not attend a deposition. Mr. Epstein also knew at that time that the undersigned had been trying to coordinate Brunel's deposition for months. Therefore, there is no doubt that Mr. Epstein was assisting Mr. Brunel and/or Ms. Kudman in obstructing discovery. At the very least, Mr. Epstein was an accomplice, but was he the person paying the attorney to make false representations and tamper with important witnesses? While Mr. Epstein may be able to invoke his 5th amendment rights on such questions, Mr. Brunel and Ms. Kudman do not have that luxury, and at this point they should be required to provide these answers.
+
+Again, as the facts make clear, Ms. Kudman has not delivered on promises made (as an officer of the court) to counsel for Jane Doe, and Mr. Brunel has not appeared for a deposition. As such, Jane Doe moves this Court to enter an order directing Mr. Brunel to promptly appear for a deposition in West Palm Beach within 14 days. He was properly served with a subpoena by Jane Doe, and only through deceitful maneuvers he has been able to avoid his deposition. This Court should not permit subpoenas to be avoided in this fashion.
+
+WHEREFORE, Jane Doe respectfully requests the Court to direct Mr. Brunel and Ms. Kudman to show cause why they should not be held in contempt for making false representations in an effort to avoid a deposition. If the Court finds that they are in
+
+CASE NO: 08-CV-80119-MARRA'
+
+contempt, the Court should also impose appropriate sanctions, including attorney's fees for Jane Doe in connection with filing this motion. The Court should also compel Mr. Brunel to appear for a deposition within 14 days of the Court's order and grant any additional relief the Court deems just and proper.
+
+# PRE-FILING CONFERENCE
+
+Counsel for Jane Doe has attempted to confer with Ms. Kudman about this motion, but she declined to make Brunel available for deposition, and in fact has again stated as recently as March 5, 2010 that Brunel has been out of the country since prior to the New Year with no plans to return.
+
+DATED: March 10, 2010
+
+Respectfully Submitted,
+
+AFFE, WEISSING, , FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com
+
+and
+
+Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu
+
+CASE NO: 08-CV-80119-MARRA'
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that on March 10, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing.
+
+> s/ J.
+
+## SERVICE LIST
+
+Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida
+
+Jack Alan Goldberger, Esq. Jaoldberger@aawoa.com
+
+Robert D. Critton, Esq. rcritton@bciclaw.com
+
+Isidro Manual isidrogarcia@bellsouth.net
+
+Jack joh@searcylaw.com •
+
+Katherine Warthen Ezell KEzell@podhurst.com
+
+Michael James Pike MPike@bciclaw.com
+
+Paul G. Cassell cassellp@law.utah.edu
+
+Richard Horace Willits lawyerswillits@aol.com
+
+Robert C. Josefsberg
+
+CASE NO: 08-CV-80119-MARRA
+
+rjosefsbera@oodhurst.com
+
+Adam D. Horowitz ahorowitz@sexabuseattorney.com
+
+Stuart S. Mermelstein ssm@sexabuseattorney.com
+
+# EXHIBIT A
+
+1 A. No.
+
+2 MR. GOLDBERGER: Form.
+
+3 BY MR.
+
+4 Q. And have you known, just based on your 5 observations, Nadia to have girlfriends? And by 6 girlfriends I mean girlfriends that she would be 7 intimate with in addition to being the girlfriend of 8 Jeffrey Epstein?
+
+9 A. No.
+
+10 Q. Do you know somebody by the name of Jean 11 Luc Brunel?
+
+12 A. Yes.
+
+13 Q. How do you know him?
+
+14 A. He was in the house like, I guess, a few 15 times.
+
+16 Q. When?
+
+17 A. When?
+
+18 Q. When was the last time you saw him there?
+
+19 A. A week ago.
+
+20 Q. Today is, what, February 16th, and this is 21 a Tuesday. So, when we are saying a week ago, are 22 you saying it was last Tuesday, Wednesday, Thursday, 23 Friday, do you remember?
+
+24 A. I don't remember the date but he stay maybe 25 three days, I think, in the house.
+
+1 Q. So, if he arrived on Tuesday, he stayed 2 through Thursday or Friday and
+
+3 A. Yes.
+
+4 Q. Do you know what the occasion was for him 5 to come in town?
+
+6 A. No.
+
+7 Q. Where did he stay in the house last week?
+
+8 A. One of the bedrooms upstairs.
+
+9 Q. And was Mr. Epstein also staying in the 10 house?
+
+11 A. Yes.
+
+12 Q. All right. Did Mr. Brunel bring any 13 company with him?
+
+14 A. No.
+
+15 Q. It was him alone?
+
+16 A. Yes.
+
+17 Q. How did he get to the house?
+
+18 A. I think he has been picked up by Igor at this 19 point.
+
+20 Q. And where did he -- I assume he flew in 21 from somewhere?
+
+22 A. Yes.
+
+23 Q. Picked up from the airport, safe 24 assumption? He didn't just drive to the airport.
+
+25 (A discussion was held off the record.)
+
+![](_page_11_Picture_24.jpeg)
+
+1 BY MR.
+
+2 Q. So, do you know where it was that
+
+3 Mr. Brunel flew in from?
+
+4 A. No.
+
+5 Q. Do you know where Mr. Brunel generally
+
+6 lives? I mean is it New York, is it
+
+7 A. I know that he spends some time in Florida, in 8 Miami, but exactly where he is, I don't know.
+
+9 Q. But obviously he wouldn't fly here to Palm 10 Beach from Miami, right, so he had to be coming from 11 somewhere else you would assume?
+
+12 A. Yes, I assume.
+
+13 Q. Were you told -- similar to the way that 14 you have been describing throughout the deposition, 15 you're told who is coming in town. Were you told he 16 was going to be at the house?
+
+17 A. Yeah. Usually he requires to be picked up, so 18 I know that he is coming.
+
+19 Q. Okay. We'll go through some other 20 instances where you had occasion to pick him up or 21 break plans, but talking specifically about last
+
+22 week: When were you first told that Mr. Brunel was 23 going to be coming into town?
+
+24 A. I think Igor told me that he has to go and 25 pick him up.
+
+1 Q. How did he --
+
+2 A. It was my day off, I guess, because usually I 3 am the one who pick up people. So, I guess it was my 4 days off and Igor was working, so he went to pick him 5 up.
+
+6 Q. Okay. It wouldn't be Story Cowles picking 7 him up?
+
+8 A. No.
+
+9 Q. So, to the best of your recollection Igo.: 10 picked up Jean Luc Brunel sometime last week from 11 the airport and took him to the house?
+
+12 A. Right.
+
+13 Q. Do you know what car he took to pick him 14 up?
+
+15 A. I think Cadillac Escalade.
+
+16 Q. The black Escalade?
+
+17 A. Yes.
+
+18 Q. And what did Mr. Brunel and Mr. Epstein do 19 for the three day stay when Mr. Brunel was staying 20 at Mr. Epstein's house last week?
+
+21 MR. GOLDBERGER: Form.
+
+22 THE WITNESS: I don't know.
+
+23 BY MR.
+
+24 Q. Did you interact, communicate with
+
+25 Mr. Brunel?
+
+1 A. Yes.
+
+2 Q. And what did he say as to why he was here?
+
+3 MR. GOLDBERGER: Form.
+
+4 THE WITNESS: Good morning. How are you?
+
+5 Exchange handshake. And I saw him in the 6 kitchen and he was cooking something and that's 7 it.
+
+8 BY MR.
+
+9 Q. When you say he was cooking something, he 10 was personally cooking?
+
+11 A. Yes.
+
+12 Q. All right. So, this is a house that he is 13 familiar enough with and he is a regular enough 14 guest that he makes himself at home?
+
+15 A. Yes.
+
+16 Q. Okay. And last week do you remember 17 anything in the three-day period that Mr. Brunel was 18 staying at the house that Mr. Brunel did from the 19 time he woke up to the time that he went to sleep?
+
+20 MR. GOLDBERGER: Form.
+
+21 BY MR.
+
+22 Q. I mean did go to the movies? Did he go to 23 the beach? Did they just hang out around the house 24 and walk?
+
+25 A. Yeah. I think he walked outside to the beach.
+
+1 He was swimming in the pool, talking on the phone just 2 what I remember.
+
+3 Q. Okay. During the three-day stay last 4 week, how often were -- I mean, I assuming that he 5 came in town to see Mr. Epstein; is that true?
+
+6 A. Yes.
+
+7 Q. And so the majority of his time during 8 that three days was spent hanging around with 9 Mr. Epstein?
+
+10 A. Yes.
+
+11 Q. All right. Did you see them talking with 12 one another?
+
+13 A. Yes.
+
+14 Q. Where were they talking with one another?
+
+15 A. In the cabana, outside sitting next to the 16 pool.
+
+17 Q. All right. And when you said that 18 Mr. Brunel walked to the beach, did Mr. Epstein walk 19 to the beach with him?
+
+20 A. No.
+
+21 Q. Mr. Brunel walked alone?
+
+22 A. Yes.
+
+23 Q. Who else was in the house last week while 24 Mr. Brunel was in the house?
+
+25 A. Nadia, Sarah, and Story, I think.
+
+![](_page_15_Picture_21.jpeg)
+
+1 Q. ?
+
+2 A. Yes.
+
+3 Q. And Story Cowles?
+
+4 A. Yes.
+
+5 Q. Okay. Who else, Igor?
+
+6 A. Igor. I guess that's it.
+
+7 8 9 Q. Did you overhear any of the substance of the conversations that Mr. Brunel was having with Mr. Epstein?
+
+10 A. No.
+
+11 12 13 Q. All right. What is your understanding as to the relationship between Mr. Brunel and Mr. Epstein?
+
+14 A. I guess they are friends.
+
+15 16 17 Q. Okay. In addition to being friends well, let me ask this question first: Do you know when they became friends?
+
+18 A. No.
+
+19 20 Q. You don't know how long they have known each other?
+
+21 A. No.
+
+22 Q. You don't know who introduced them?
+
+23 A. No.
+
+24 25 Q. They could have met since they were five years old or they could have met five years ago for 1 all you know?
+
+2 A. Yes.
+
+3 Q. In addition to being friends, do you know 4 them to be -- have a business relationship with one 5 another?
+
+6 A. I don't know.
+
+7 Q. Do you know what Mr. Brunel does for a 8 living?
+
+9 A. I think he has some modeling agency, owner of 10 some modeling agency. I don't know exactly where, which 11 one.
+
+12 Q. Why do you think that? Why do you think 13 he is involved with a modeling agency?
+
+14 A. I think somebody told me.
+
+15 Q. Okay. That's fair enough. Who?
+
+16 A. I don't remember who.
+
+17 Q. Would it be Sarah or Mr. Epstein?
+
+18 A. It could be.
+
+19 Q. And whether it was Sarah or -- whoever 20 told you about this was one of the people that you 21 have previously described as being within the 22 Jeffrey Epstein organization?
+
+23 A. Yes.
+
+24 Q. And as you sit here today, you can't say 25 definitely it was one person within the organization
+
+![](_page_17_Picture_21.jpeg)
+
+1 A. No. She was a guest, I assume.
+
+2 Q. Any reason why there would be an overlap 3 between her staying at the house and Jean Luc 4 staying at the house, or it was just coincidence as 5 far as you could tell?
+
+6 A. I don't know.
+
+7 Q. 8 written Okay. And is there anywhere where you've down or documented what Sue's last name is?
+
+9 A. No.
+
+10 Q. Did you take her back to the airport?
+
+11 A. Yes.
+
+12 Q. 13 airport? And what day did you take her to the
+
+14 A. Yesterday.
+
+15 Q. Yesterday. So, she was here four days.
+
+16 She got here last Thursday or Friday?
+
+17 A. I think Friday.
+
+18 Q. And she was at the house for a period of 19 time when Jean Luc Brunel was at the house?
+
+20 A. Yeah. I mean, last week, yes.
+
+21 Q. Okay. So, she got there Friday. When did 22 Jean Luc Brunel finally leave Mr. Epstein's house?
+
+23 A. I think Monday, yeah, Monday. He left Monday.
+
+24 Q. That's yesterday?
+
+25 A. Or Sunday.
+
+![](_page_18_Picture_24.jpeg)
+
+1 Q. Today is Tuesday.
+
+2 A. Today is Tuesday. Yes, I think Sunday.
+
+3 4 Q. Okay. So, on Sunday Jean Luc Brunel left and on Monday Sue left?
+
+5 A. Yes.
+
+6 7 Q. All right. Did you take Jean Luc Brunel to the airport?
+
+8 A. No.
+
+9 Q. All right. Did Igor?
+
+10 A. Sarah.
+
+11 12 4. . And do you know where he was flying to?
+
+13 A. No.
+
+14 15 Q. You don't know where he came from or where he was flying to?
+
+16 A. Right.
+
+17 18 19 20 21 Q. Right. And as of right now you have no knowledge as to where he primarily resides, whether that -- I know you said that he spends some time in Miami, but whether he primarily resides in Miami or New York or Antartica, you have no idea?
+
+22 A. No.
+
+23 24 25 Q. Okay. Other than last week, when was the last time that you saw this gentleman Jean Luc Brunel at Jeffrey Epstein's house?