Epstein Secrets

ORDER [DE 536] Plaintiff, Jane Doe, hereby files this response to Defendant Epstein’s Motion for A Protective Order Regarding the Deposition of Story Cowles [DE 536]. The motion should be denied in its entirety, as Cowles possesses non-privileged information and any true attorney-client information he

fendant Epstein’s Motion for A Protective Order Regarding the Deposition of Story Cowles [DE 536]. The motion should be denied in its entirety, as Cowles possesses non-privileged information and any true attorney-client information he possesses obviously need not be disclosed during his deposition.

aw.com Isidro Manual 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 rjosefsberg@p

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

IMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. PALI GREGORY W. COLEMAN. PA ROBERT D. CRITTON, JR.. PA' BERNARD A- LEUDEKER MARK T. LUTTIER. PA MICHAEL J. PIKE DAVID A. YAREMA 'FLORIDA WARD CERTIFIED CIVIL TRIAL LAWYER 2ADAUTTED TO PRACTICE IN FLORIDA AND COLORADO April 26, 2010 Sent via U.S. Mail Jack

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

erence call that Mr. Cowles would not be deposed if Ms. Kellen was 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 wr

ho pick up people. So, I guess it was my 4 days off and Igor was working, so he went to pick him 5 up. 6 Q. Okay. It wouldn't be Story Cowles picking 7 him up? 8 A. No. 9 Q. So, to the best of your recollection Igor 10 picked up Jean Luc Brunel sometime last we

aw.com Isidro Manual 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 Case 9:08-cv-

nother district, stoic here: ) SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION 'ro: Story Cowles, 801 South Okve Avenue, #201S. West Palm Beach, FL 33401 O Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the

Southern District of Florida Jack Alan Goldber er, Esq. Robert D. Critton, Esq. Isidro Manual Garcia Jack Patrick Hill Katherine Warthen Ezell Michael James Pike Paul G. Cassell Richard Horace Willits Robert C. Josefsber Adam D. Horowitz Stuart S. Mermelstein 3 EFTA00728297 AO SYli I Rry ;ram IANtice

IKE: Form. 0100 1 A. I refuse to answer. 2 Q. Do you know how it is that met 3 Jeffrey Epstein? 4 A. I refuse to answer. 5 Q. Do you know Story Cowles? 6 A. I refuse to answer. 7 Q. You know who Sergio Cordero is? 8 A. I refuse to answer. 9 Q. Well, that's somebody who also assists 10 Mr.

m Beach, Florida 33401 12 3524-006 Page I of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009248 EFTA00159250 BY: MICHAEL J. PIKE, ESQ. 13 14 ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES: 15 KERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard 16 Suite 2218 Miami, Fl

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

a conference call that Mr. Cowles would not be deposed if Ms. was 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 wr

# 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

Suite 1400 West Palm Beach , FL 33401-5012 USA Martin G. Weinberg PRO HAC VICE;ATTORNEY TO BE NOTICED 20 Park Plaza Boston , MA 02116 A Fax: Michael James Pike ATTORNEY TO BE NOTICED Burman Critton Luttier & Coleman 303 Banyan Boulevard Suite 400 West Palm Beach , FL 33401-2918 A Michael Ross Tein [Te

am the one who pick up people. So, I guess it was my 4 days off and Igor was working, so he went to pick him 5 up. 6 Q. Okay. It wouldn't be Story Cowles picking 7 him up? 8 A. No. 9 Q. So, to the best of your recollection Igor 10 picked up Jean Luc Brunel sometime last week from 11 the air

t, Southern District of Florida Jack Alan Goldber er Esq. Robert D. Critton Esq. Isidro Manual Garcia Jack Patrick Hill Katherine Warthen Ezell Michael James Pike Paul G. Cassell Richard Horace Willits Robert C. Josefsberg 8 EFTA01660098 Case 9:08-cv-80119-KAM Document 483 Entered on FLSD Docket 03/10/20