Epstein Secrets

discovery and thus preventing Epstein from deposing third parties, including two individuals that were Jane Doe 4's soccer coaches for years (i.e., Rocky Orezzoli and Bill Brown). Limiting such discovery would undoubtedly result in reversible error. Plaintiff claims Epstein is harassing her by way of seeking

tf Order, and for such other and further relief as this court By _ __,f-------c;,.LC.--,,<-------- ROBER . RITTON, JR., ESQ. Florida Bar #224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERT. Y that a true copy of the foregoing was being served this day on all counsel of

fe or her daughter making a video. See Exhibit 4, deposition excerpt of Jane Doe No. 4’s mother. 7. Defendant now wants to take the deposition of Rocky Orezzoli, Jane Doe No. 4’s college soccer coach, and Bill Brown, Doe No. 4’s soccer coach in middle and high school. The past conduct of Epstein’s counsel

outh.net Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits

and states as follows: 1. Plaintiff Jane Doe No. 4’s Motion for Protective Order (“Motion”) is now moot, in part, with regard to the deposition of Rocky Orezzoli, as Mr. Orezzoli was deposed by Defendant Epstein’s counsel on April 30, 2010, while the Motion was pending. However, the Motion remains ripe with

Isidro Manuel Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg rjosefs