EFTA02728774.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08.CV-80119-MARRAIJOHNSON 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, DECLARATION OF ADAM D. HOROWITZ 1. My name is Adam D. Horowitz. l am an attorney for Jane Doe 2. The deposition of Jane Doe =vas scheduled for September 16, 2009 at 1:00 p.m. a On the day before the in deposition, the undersigned and counsel for Jeffrey Epstein entered into a written stipulation which it was agreed that "Jeffrey Epstein will not attend tomorrow's deposition of Jane Doe. El(in the absence of a court order permitting him to attend)." It was further agreed that Jeffrey Epstein may listen in to the deposition by telephone or view a videofeed of the deposition, but under no circumstances would he "be seen by our client." 3. While Jane DoeMind I were in the lobby of paths with approximately 1:00 p.m. for her deposition on September 16, 2009, we crossed Jeffrey Epstein and someone who appeared to be his bodyguard. Jeffrey Epstein stopped EXHIBIT I A 09/1212019 Agency to Agency Requet 19-411 CONFIDENTIAL SDNY_GM_00330126 EFTA 00202852 EFTA02728774 walking and began to stare at and intimidate Jane Doe Jane Davas terrified, began crying and ran outside the building. Jeffrey Epstein smirked at her and walked away. 4. As a result of this incident, Jane Doe began crying uncontrollably and was unable to proceed with her deposition. Under penalties of perjury I declare that I have read the foregoing Declaration and the facts stated in it are true. Dated: September /7 2009 0 —Ali Adam D. Horowitz 2 09112/2019 Pape97 Agency to Agency Requet 19-411 CONFIDENTIAL SDNY_GM_00330127 EFTA 00202853 EFTA02728775