Epstein Secrets

that Epstein be prevented from attending her deposition should be denied. See Anderson v. Snyder, 91 Conn. 404,408, 99 A. 1032 (1917); Helfferich v. Farley, 36 Conn.Sup. 333,334, 419 A.2d 913 (1980). If this Court excludes Defendant from deposition, Plaintiffs deposition Case 9:08-cv-80119-KAM Docu

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

her deposition and that a special master be appointed should be denied. See Anderson v. Snyder, 91 Conn. 404, 408, 99 A. 1032 (1917); Helfferich v. Farley, 36 Conn.Sup. 333, 334, 419 A.2d 913 (1980). If this Court excludes Defendant from deposition, Plaintiffs deposition testimony could be stricken fro

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.

of depositions as well as during the examination of witnesses at trial." See Anderson v. Snyder, 91 Conn. 404, 408, 99 A. 1032 (1917); Helfferich v. Farley, 36 Conn.Sup. 333,334,419 A.2d 913 (1980). Case 9:08-cv-80119-KAM Document 370 Entered on FLSD Docket 10/23/2009 Page 5 of 8 Page 5 Certif

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