EFTA01076797.pdf

BURM.AN. CRITTON LUTTIER&COLEMAN,ES TRUSTED LLP ADVOCAT YOUR A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. PA' ADELE:all J. BENAVENTE ENIALEGAL/iNvESNGATOI GREGORY W. COLEMAN. PA ROBERT D. CRITTON, JR.. PA' JESSICA CADWELL BERNARD A- LEUDEKER BOBBIE M. MCKENNA MARK T. LUTTIER. PA ASHLIE STOKEN-BARING MICHAEL J. PIKE BETTY STOKES PARALEGALS DAVID A. YAREMA RITA H. BUDNYK 'FLORIDA WARD CERTIFIED CIVIL TRIAL LAWYER Of COUNSEL 2ADAUTTED TO PRACTICE IN FLORIDA AND COLORADO EDWARD M. RICCI Of COUNSEL April 26, 2010 Sent via U.S. Mail Jack A. Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401 Protective Re: Jane Doe v. Epstein, Case No. 08-CV-80893 - Motion for Order re: Deposition of Story Cowles Dear Jack: Mike Pike in support of Enclosed are the original executed affidavits of Bob Critton and Story Cowles, which are the Motion for Protective Order Regarding the Deposition of exhibits to the motion. Do not hesitate to contact me if you have any questions. 303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH. FL 334O1 • PHONE: WWW.BCLC LAW.COM EFTA01076797  T UNITED STATES DISTRICT COUR A SOUTHERN DISTRICT OF FLORID JJOHNSON CASE NO.: 08-CIV-80119-MARRA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / Related cases: 4, 08-80232, 08-08380, 08-80381, 08-8099 08-80993, 08-80811, 08-80893, 09-80469, 2 09-80591, 09-80656, 09-80802, 09-8109 / ESQ. AFFIDAVIT OF MICHAEL J. PIKE, STATE OF FLORIDA ) SS COUNTY OF PALM BEACH ) having personally appeared Michael Pike, Esq., BEFORE ME, the undersigned authority, deposes and says: personal knowledge and being duly sworn, law firm of Burman, Critton, Luther & I. I, Michael Pike, am an attorney at the in the civil case s and claims asserted against him in this Coleman, LLP and represent Mr. Epstein and related actions. phone conferences with Spencer Kuvin, 2. In or around October, 2009, 1 had tele . panion stat e court case) and Bradley Edwards, Esq Esq. (counsel for Plaintiff, B.B., in a com were ., Plaintif fs in companion state court cases), who (counsel for Jane Doe and E.W. and L.M seeking to depose Story Cowles. EFTA01076798  was produced for 3. Mr. Kuvin and Mr. Edwards agreed that if was attempting to effectuate service of deposition, they would not depose Mr. Cowles. Each Goldberger, Esq. process one and also knew that Mr. Cowles is an employee of Jack is reneging on 4. was produced for deposition and now Mr. Edwards his end of the bargain. FURTHER THE AFFIANT SAYETH NAUGHT Mi rice, Esq. STATE OF FLORIDA COUNTY OF PALM BEACH r duly authorized to administer I hereby Certify that on this day, before me, an office ael J. Pike known to me to be the oaths and take acknowledgments, personally appeared Mich Affidavit, who acknowledged before me person described in and who executed the foregoing ing form of identification of the above that he/she executed the same, that I relied upon the follow named person: , and that an oath was/was not taken. last aforesaid this S. hand and official seal in the County and State leday of VII , 2010. NAME: ((SEAL) NOTARY PUBLIC/STATE OF FLORIDA COMMISSION NO.: MY COMMISSION EXPIRES: 1Priel1 CADWELL :4 MY COMIA6SKAV 8S3523 EXPIRES: apri 19, 2013 Blisu Notary Patic Usteralles A 2 EFTA01076799  COURT UNITED STATES DISTRICT FLORIDA SOUTHERN DISTRICT OF 119-MARRA/JOHNSON CASE NO.: 08-CIV-80 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. I Related cases• 08-80994, 08-80232, 08-08380, 08-80381, 09-80469, 08-80993, 08-80811, 08-80893, 09-81092 09-80591, 09-80656, 09-80802, CRITTON, JR., ESQ. AFFIDAVIT OF ROBERT D. ) SS STATE OF FLORIDA ) COUNTY OF PALM BEACH ed authority, personally app eared Robert D. Critton, Jr., BEFORE ME, the undersign s: and bei ng duly sworn, deposes and say Esq., having personal knowledge LLP of Burm an, Critton, Luttier & Coleman, 1. 1, Robert Critton, and the law firm related civil cases and claims ass erted against him in this and represent Mr. Epstein's in the actions. legal that Story Cowles has been employed as a 2. It was and is my understanding . since July 2008. assistant for Jack Goldberger, Esq ormation it attorney-client and work product inf 3. I have used Mr. Cowles to transm clear and other attorneys representing Mr. Epstein with the and documents to Mr. Epstein EFTA01076800  in, his attorneys and staff understating and belief that the communications among Mr. Epste eges. would be protected by the attorney-client and work product privil FURTHER THE AFFIANT SAYETH NAUGHT. Robert D. ► ritton, Jr., Esq. STATE OF FLORIDA COUNTY OF PALM BEACH rized to administer I hereby Certify that on this day, before me, an officer duly autho n known to me to be the oaths and take acknowledgments, personally appeared Robert Critto who acknowledged before me person described in and who executed the foregoing Affidavit, of identification of the above that he/she executed the same, that I relied upon the following form named person: , and that an oath was/was not taken. aforesaid this W S my hand and official seal in the County and State last day of ti , 2010. ae-e' 4.4-7-45FAL) NOTARY PUBLIC/STATE OF FLORIDA COMMISSION NO.: MY COMMISSION EXPIRES: JESSCACADWELL tit MY COMMISSION P DO PISW9 1 WOO Thu Nary Petic91UTZMers 2 EFTA01076801