EFTA02729703.pdf

Case 9:08-O/-80119-KAM Document 305-11 Entered on FLSD Docket 09/17/2009 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08.80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80581, 09-80656, 09-80802, 0941092. ORDER ON DEFENDANT'S, JEFFREY EPSTEIN, MOTION FOR SANCTIONS AND TO COMPEL DEPOSITION OF JANE DOE NO.4 AND MEMORANDUM IN SUPPORT THEREOF This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion For Sanctions and to Compel Deposition of Jane Doe No. 4. Having considered Defendant's motion, it is HEREBY ORDERED and ADJUDGED that: Defendant's motion is hereby GRANTED: Plaintiff shall pay sanctions in the amount of S in costs and S in fees directly to Burman, Critton, Luther and Coleman within 10 days, and further directs that the Plaintiff make herself available for deposition no later than October , 2009 beginning at 9:30 a.m. at the same location. Mr. Epstein shall not be present in the building on the day of the deposition absent a court order on • pending motions. 09/1212019 Agency to Agency Requet: 19-411 CONFIa153ENTIAL SDNY_GM_00331993 EFTA 00204719 EFTA02729703 Case 9:08-cv-80119-KAM Document 305-11 Entered on FLSD Docket 09/17/2009 Page 2 of 2 Jane Doe No. 4 v. Epstein Page 2 DONE and ORDERED this day of .2009. Kenneth A. Marra United States District Judge Courtesy Copies: Counsel of Record 09/12/2019 Agency to Agency Requet: 19-011 CONFIDE CONFIDENTIAL P SDNY_GM_00331994 EFTA 011204720 EFTA02729704  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. MI:FREY 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. 1am an attorney for Jane Doe No. 4. 2. The deposition of Jane Doe No. 4 was scheduled for September 16, 2009 at 1:00 p.m. at 350 Australian Ave. South, Suite 115, West Palm Beach, Florida. On the day before the deposition, the undersigned and counsel for Jeffrey Epstein entered into a written stipulation in which it was agreed that "Jeffrey Epstein will not attend tomorrow's deposition of Jane Doe No. 4 (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 Doe No. 4 and I were in thc lobby of 350 Australian Ave South at approximately 1:00 p.m. for her deposition on September 16, 2009, we crossed paths with Jeffrey Epstein and someone who appeared to be his bodyguard. Jeffrey Epstein stopped 09/12/2019 Agency to Agency Reque;: 19-411 SDNY_GM_00331995 EFTA_0020472I EFTA02729705  walking and began to stare at and intimidate Jane Doc No. 4. Jane Doe No. 4 was 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 17, 2009 Adam D. Horowitz "141 / 2 09112/2019 Agency to Agency Requet: 19-411 CONFIDENTIAL Pa SDNY_GM_00331996 EFTA_00204722 EFTA02729706  C) Jeffrey J. Colbath Circuit Court Judge 205 North Dixie Highway z West Palm Beath, FL 33401 016H26510904 m $00.449 10/05/2009 NANA preen 33401 US POSTAGE Barbara Burns, Esq., State Attorney's Office - 401 North Dixie Highway West Palm Beach, FL 33401 as 33401$4296 0021 WholinhdlimadAddhh.fluhh dd.O.d L661£C00- V4O- ANOS IJ EFTA02729707 Jeffrey Epstein #W35755 Page 1 of 2 • Wyetha Harris From: Barbara Bums Sent: Tuesday, February 16, 2010 2:34 PM To: Wyetha Hams Subject: RE: Jeffrey Epstein #W35755 Yes, all of the victims were included in the No Contact. Thanks!!!! From: Wyetha Harris Sent: Tuesday, February 16, 2010 2:31 PM To: Barbara Bums Subject: RE: Jeffrey Epstein #W35755 Per STAC there is only one in the 2008 case. Do you want me to send the two in the 2006 case? From: Barbara Bums Sent: Tuesday, February 16, 2010 2:24 PM To: Wyetha Harris Subject: RE: Jeffrey Epstein #W35755 VVy. there are three. We should only use initials and addresses. Thanks!!! From: Wyetha Harris Sent: Tuesday, February 16, 2010 2:09 PM To: Barbara Burns Subject: FW: Jeffrey Epstein #W35755 Barbara, do you want me to give her full name? From: Elkins, Candice [mailto:[email protected]] Sent: Tuesday, February 16, 2010 1:58 PM To: Wyetha Harris Subject: RE: Jeffrey Epstein #W35755 2008 case From: Sloane, Carmen Sent: Tuesday, February 16, 2010 1:56 PM To: Elkins, Candice Subject: FW: Jeffrey Epstein #W35755 Forward to you From: Wyetha Harris [mailto:[email protected]] Sent: Tuesday, February 16, 2010 10:56 AM To: Sloane, Carmen Subject: FW: Jeffrey Epstein #W35755 09/12/2019 Agency to Agency Requet: 19-011 2/16/2010 CONFIDENTIAL T SDNY_GM_00331998 EFTA 00204724 EFTA02729708  Jeffrey Epstein #W35755 Page 2 of 2 . • • The 2006 or 2008 case? From: Barbara Bums Sent: Monday, February 15, 2010 10:09 AM To: Wyetha Harris Subject: FW: Jeffrey Epstein #W35755 Could you please provide this info to Carmen. Thanks!!! From: Sloane, Carmen [mallto:[email protected]] Sent: Thursday, February 04, 2010 11:21 AM To: Barbara Burns Cc: Sloane, Carmen Subject: Jeffrey Epstein #W35755 Second Request Hi, Can you please email me the victim's addresses, I need to send them a No Contact letter from DOC. Thanks. Carmen Posse note. Ronda has a very broad public records law Most written communications lo or from state officials regarding slate business are public records mailable to the pubic end media upon request. Your communications may therefore be subplot to public disclosure 09/12/2019 Agency to Agency Requet: 19-011 2/16/2010 CONFIDENTIAL PT SDNY_GM_00331999 EFTA_00204725 EFTA02729709