Epstein Secrets

in in the civil cases and claims asserted against him in this and related actions. 2. In or around October, 2009, 1 had telephone conferences with Spencer Kuvin, Esq. (counsel for Plaintiff= in a companion state court case) and Bradley Edwards, Esq. (counsel for Jane Doe ma and M., Plaintiffs in companion

Esq. (counsel for Jane Doe ma and M., Plaintiffs in companion state court cases), who were seeking to depose Story Cowles. EFTA00611617 3. Mr. Kuvin and Mr. Edwards agreed that in.= was produced for deposition, they would not depose Mr. Cowles. Each was attempting to effectuate service of proce

UDNYK Of COUNSLL EDWARD EA RICCI Of COUNSEL Re: Jane Doe v. Epstein, Case No. 08-CV-80893 - Motion for Protective Order re: Deposition of Story Cowles Dear Jack: Enclosed are the original executed affidavits of Bob Critton and Mike Pike in support of the Motion for Protective Order Regarding the De

tate court case) and Bradley Edwards, Esq. (counsel for Jane Doe ma and M., Plaintiffs in companion state court cases), who were seeking to depose Story Cowles. EFTA00611617 3. Mr. Kuvin and Mr. Edwards agreed that in.= was produced for deposition, they would not depose Mr. Cowles. Each was attempting

as made available for her deposition, which she was in April, 2010. See Affidavit of Michael J. Pike attached as Exhibit F and 10/13/09 E-mail from Spencer Kuvin attached as Exhibit G. While counsel for Jane Doe did not confirm this agreement in writing, he represented same in the aforementioned telephone co

hed as Exhibit F and 10/13/09 E-mail from Spencer Kuvin attached as Exhibit G. While counsel for Jane Do

t, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 26(c), Federal Rules of Civil Procedure, moves for a protective order to prohibit the deposition of Story Cowles, and states: 1. Plaintiff, Jane Doe (Case No. 08-80893), noticed the deposition of Story Cowles for May 12, 2010 (Notice and Subpoena attached as

as made available for her deposition, which she was in April, 2010. See Affidavit of Michael J. Pike attached as Exhibit F and 10/13/09 E-mail from Spencer Kuvin attached as Exhibit G. While counsel for Jane Doe did not confirm this agreement in writing, he represented same in the aforementioned telephone co

hed as Exhibit F and 10/13/09 E-mail from Spencer Kuvin attached as Exhibit G. While counsel for Jane Do

t, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 26(c), Federal Rules of Civil Procedure, moves for a protective order to prohibit the deposition of Story Cowles, and states: I. Plaintiff, Jane Doe (Case No. 08-80893), noticed the deposition of Story Cowles for May 12, 2010 (Notice and Subpoena attached as

25 PAGE 45 APPEARANCES (CONTINUED) 2 LEOPOLD-KUVIN Attorneys for Plaintiffs 3 II. B. and CI'. 29

owles about 15 this case on numerous occasions; is that true? 16 MR. YAREMA: Object to the form. 17 A Fifth. 18 conversations with Story 19 Cowles and your observations of them, you believe 20 would implicate you in a crime and that's why 21 you're able to take the Fifth as to that 22 ques

owles From: Jeffrey Epstein Sent Wed 1/20/2010 10:06:57 PM Subject: Re: ys On Wed, Jan 20, 2010 at 4:41 PM, Story Cowles Wrote: The only day Kuvin can meet is Monday at 10am. You have the Hunt depo at Jacks office at 1pm that day. Is this ok? Sent from Story's iPhone *t*t*t*t*t*t*t*****t*t*t*

To: Story Cowles From: Jeffrey Epstein Sent Wed 1/20/2010 10:06:57 PM Subject: Re: ys On Wed, Jan 20, 2010 at 4:41 PM, Story Cowles Wrote: The only day Kuvin c

frey Epstei Sent Thur 1/7/201010:08:15 PM Subject: Re: ask darren On Thu, Jan 7, 2010 at 5:05 PM, Story Cowles Have we received a response from Kuvin for the bar complaint? Sent from Story's iPhone ******* *************** ******** ****** ********** ************ The information contained in

To: Story Cowles( From: Jeffrey Epstei Sent Thur 1/7/201010:08:15 PM Subject: Re: ask darren On Thu, Jan 7, 2010 at 5:05 PM, Story Cowles Have we received a r

To: Jeffrey Epstein[[email protected]] From: Story Cowles Sent Thur 1/7/2010 10:05:16 PM Have we received a response from Kuvin for the bar complaint? Sent from Story's iPhone EFTA_R1_01503022 EFTA02432374

To: Jeffrey Epstein[[email protected]] From: Story Cowles Sent Thur 1/7/2010 10:05:16 PM Have we received a response from Kuvin for the bar complaint? Sent from Story's iPhone EFTA_R1_01503022 EFTA024323

, 2010 Associated Cases: 9:08-cv-80119-KAM et al.(Kuvin, Spencer) (Entered: 06/14/2010) 567 RESPONSE/R

# 2 Exhibit B)(Edwards, Bradley) (Entered: 05/17/2010) 548 REPLY to Response to Motion re 536 MOTION for Protective Order Regarding Deposition of Story Cowles and Incorporated Memorandum of Law RE Deposition of Story Cowles filed by Jane Doe II. (Goldberger, Jack) (Entered: 05/17/2010) 549 Unopposed MOTIO