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esses. Thus, Epstein has a Sixth Amendment right to attend the depositions under the Confrontation Clause of the Federal Constitution. Christian v. Rhode, 41 F.3d 461, 465-66 (C.A. Ariz. 1994). See also, Coy v. Iowa, 487 U.S. 1012, 1015, 108 S.Ct. 2798, 2800, 101 L.Ed.2d 857 (1988). The Clause "guaran
t met the exceptional burden of proving to this court that Epstein should be excluded from her deposition. Plaintiff adopts and incorporates all of Jane Doe 2-S's argument with only one additional argument (i.e., that if this court allows Epstein to attend Jane Doe's deposition it would violate the right o
ending the case in the normal course of conducting discovery and filing motions would not be a breach? (Ex. "A," p.30). Mr. Horowitz - counsel for Jane Does 2-7: Subject to your rulings, of course, yes. (Ex. "A," p.30). *** The Court: But you're not taking the position that other than possibly doing s
what Mugrage 'd z prov1 es. 2 In addition, Epstein offers a more restrictive setting than what is permitted under the law. See ~-, Christian v. Rhode, 41 F.3d 461, 465-66 (C.A. Ariz. 1994). See also, Coy v. Iowa, 487 U.S. 1012, 1015, 108 S.Ct. 2798, 2800, 101 L.Ed.2d 857 (1988). The Clause "guaran
tor is located. f. Once the deposition is over, Epstein will remain located in the room where the video- feed monitor is located until such time as Jane Doe 4 and her attorney have exited the building, which her attorney will confirm by cellular telephone with the undersigned. DONE and ORDERED this -~day
of 13 Page4 Epstein has a Sixth Amendment right to attend the depositions under the Confrontation Clause of the federal Constitution. Christian v. Rhode, 41 F.3d 461, 465-66 (C.A. Ariz. 1994). See also, Coy v. Iowa, 487 U.S. 1012, 1015, 108 S.Ct. 2798, 2800, 101 L.Ed.2d 857 (1988). The Clause "guara
D MEMORANDUM OF LAW Defendant, Jeffrey Epstein, ("Epstein") by and through his undersigned counsel, serves his Response In Opposition to Plaintiff Jane Doe No. 4's Motion for Sanctions and Motion for Protective Order, With Incorporated Memorandum of Law In support, Epstein states: I. Introduction 1.
Entities connected to both Rhode and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSONMaria Farmer
PERSONRobert D. Critton
PERSON
George W. Bush
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSONSouthern District
LOCATION
Salt Lake City
LOCATION
Alexander Acosta
PERSONScott Rothstein
PERSON
A. Marie Villafana
PERSONRobert C. Josefsberg
PERSON