Epstein Secrets

ot meet the threshold requirements for the imposition of the waiver of liability portion of Paragraph 8 of the NPA is demonstrated by the filings of Jane Doe II in 09-80469-CIV-Marra, a federal lawsuit filed in March, 2009 seeking "exclusively 2255" damages, while Jane Doe I1 already bad a pending state cou

d to resolve any fee related issues that the Podhurst firm and Mr. Epstein's civil counsel cannot resolve. See Exhibit 20, June 15, 2009 Letter from Robert Critton to Kathy Ezell. There is nothing about the exchanges between counsel and the USAO regarding the attorney representative that even begins to approac

ot meet the threshold requirements for the imposition of the waiver of liability portion of Paragraph 8 of the NPA is demonstrated by the filings of Jane Doe II in 09-80469-CIV-Marra, a federal lawsuit filed in March, 2009 seeking "exclusively 2255" damages, while Jane Doe I1 already bad a pending state cou

d to resolve any fee related issues that the Podhurst firm and Mr. Epstein's civil counsel cannot resolve. See Exhibit 20, June 15, 2009 Letter from Robert Critton to Kathy Ezell. There is nothing about the exchanges between counsel and the USAO regarding the attorney representative that even begins to approac

verned discovery. 9. Interestingly, in Jane Doe 11, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is despite her claims of "emotional trauma" set forth in her complaint. Jane Doe No. 11 is also a Plai

et: 19-411 SDNY_GM_00331977 EFTA_00204703 EFTA02729687 Case 9:08-cv-80119-KAM Document 305-4 Entered on FLSD Docket 09/17/2009 Pirafgbef ar 2 Robert D. Critton Jr. From: Adam Morowitz iahorowitzesexabuseetbxney.corni Sent: Tuesday, September 15, 2009 11:43 AM To: Michael J. Pike; Robert D. Critton Jr. Cc:

5 N Andrews Avenue Suite 2 Fort Lauderdale , FL 33301 USA ti EFTA01660040 Jane Doe No. 102 Consol Plaintiff Jane Doe No. 101 Consol Plaintiff Jane Doe II Consol Plaintiff Jane Doe No. 6 Consol Plaintiff Katherine Warthen Ezell LEAD ATTORNEY;ATTORNEY TO BE NOTICED Podhurst Orseck Josefsberg et al

d before Judge Kenneth A. Marra: Status Conference held on 5/6/2010. Adam Horowitz, Bradley Edwards, Katherine Ezell f r PI in iff nd Michael Pike, Robert Critton for Defendant. Court Reporter: Stephen Franklin, [email protected] (ir) (Entered: 05/06/2010) 539 Defendant's MOTION for Summary J

ontinue to attempt to control how discovery is conducted in this case and how this court has historically governed discovery. 9. Interestingly, in Jane Doe II, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition.

Co-Counsel for Defendant Jeffrey Epstein) EFTA00182053 • Case 9:08-cv-80119-KAM Document 305-4 Entered on FLSD Docket 09/17/2009 PRttlacif of 2 Robert D. Critton Jr. From: Adam Horowitz Sent Tuesday, September 15, 2009 11:43 AM To: Michael J. Pike; Robert D. Critton Jr. Cc: Stuart Mermelstein Subject Jane

: Other Docket: Jurisdiction: 03/24/2009 Judge Kenneth A Marra Personal Injury (360) Federal Question None None Federal Question Litigants Jane Doe II Plaintiff Jeffrey Epstein Defendant Class Code: CLOSED Closed: Yes Statute: 28:1331 Jury Demand: Plaintiff Demand Amount: $0 NOS Description

d before Judge Kenneth A. Marra: Status Conference held on 5/6/2010. Adam Horowitz, Bradley Edwards. Katherine Ezell for Plaintiff and Michael Pike, Robert Critton for Defendant. Court Reporter: Stephen Franklin. 561-514-3768 / [email protected] (ir) (Entered: 05/06/2010) 05/06/2010 539 Def

Incorporated Memorandum of Law by Jeffrey Epstein. (Pike. Michael) (Entered: 06/09/2010) 06/14/2010 162 Emergency MOTION for Protective Order by Jane Doe II. Associated Cases: 9:08-cv-80119-KAM et al.(ots) (Entered: 06/14/2010) 06/14/2010 163 NOTICE by Jane Doe re (565 in 9:08-cv-80119-KAM) MOTION for

164 Minute Entry for proceedings held before Judge Kenneth A. Marra: Telephonic Status Conference held on 6/16/2010. Brad Edwards for Plaintiff and Robert Critton for defendants. Parties to submit witness list by 6/21/10 and exhibit list by 6/25/10. Court Reporter: Stephen Franklin. 561-514-3768 / Stephen_Fra

ontinue to attempt to control how discovery is conducted in this case and how this court has historically governed discovery. 9. Interestingly, in Jane Doe II, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition.

-Counsel for Defendant Jeffrey Epstein) EFTA01625684 • Case 9:08-cv-80119-KAM Document 305-4 Entered on FLSD Docket 09/17/2009 PR4121acif ?If 2 Robert D. Critton Jr. From: Adam Horowitz tahorowitz(sexabuseettomey.corn) Sent Tuesday, September 15, 2009 11:43 AM To: Michael J. Pike; Robert D. Critton Jr. Cc: