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Australian A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 iagesq(cv,bellsouth.net Counsel for Defendant Jeffi'ey Epstein Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq .. Adam D. Horowitz, Esq.
:/ EPSTEIN'S MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF STORY COWLES AND INCORPORATED MEMORANDUM OF LAW Defendant, 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:
as hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on I July 16, 2008 and has been employed by Mr
esq(cv,bellsouth.net Counsel for Defendant Jeffi'ey Epstein Certificate of Service Jane Doe No. 2 v. Jeffre
pstein Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stua
iscussed the claims asserted against him with Mr. Cowles other than when his attorneys were present or when he was transmitting information between Epstei11 and his attorneys. See Exhibit C. 2 i I ! Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 3 of 8 9. In Octob
uct privilege and that any communications between the investigator and attorneys and staff were protected by the attorney-client privilege); Huet v. Tromp, 912 So. 2d 336 (Fla. 5th DCA 2005) (quashing trial comfs discovery order denying motion for protective order to -prohibit deposhion of defendant's
reates big investment profits for billionaire clients without revealing how he does it or whose portfolios he ban, dies. But now, investment whiz Jeffrey Epstein's darkest personal secrets have allegedly been bared in an ex- plosive, seamy prostitution case in- volving underage girls Instead of marveling at hi
element as far as the age is concerned." Dekle said. After an 11-month investi- gation, Palm Beach police said there was probable cause to charge Epstein. 53. with unlawful sex acts with a minor Epstein: Two politicians have returned dona- tions since he was charged with soliciting minors. and
r jurors were then called into Brown's courtroom one by one and asked if they had heard VA 5.1.4.‘E sLir wrwrire °MIMS Moore was a juror in the Jeffrey limb murder trial until it was discovered she neglected to disclose her daughter's murder. Moore say anything about her life that had relevance t
house to give him massages, Goldberg- er said. "Mr. Epstein absolute- ly insisted anybody who came to his ho
. provide evidence that he knew the girls were teenagers. One girl couldn't show up when Mr. Epstein wanted because she had soccer Another time. Mr Ep- stein had to wait for his "massage session because the girl he wanted was still in class. Why didn't State Attorney Barry Krischer let a jury decide wh
638 OCC 0 ), r Cr C X • For The Most Current Rates & Information Visit Us Online At ig://www.palmbeach Payment Calculator 1St" sroprg 33"er Tromp" pp, an "nes rronnypryouttag ITT ** TIN %an ray' Ihreeeerrarr PiregiOrd rim 558wismuto tool eta SIM* tarsus Faint". 174 pare. co an 15% 4110.87330
ROPE OR THE UK ACKNOWLEDGED THEIR INVOLVEMENT IN EPSTEINS CRIMES!!! I WAS EVEN TAKEN TO EPSTEINS HOUSE DEL
RESTED ME YOU ARSHOLES!!! 'As I have explained in the past, and presumably Sigrid has as well, you received one of the highest settlements against Jeffrey Epstein in the past." ATTACHED ARE SARAH KELLENS EAMILS AND MY PHOTOS OF HER, m MMUST SE A WITNESS I Sent with Pmtrin Mad secure email. EFTA00144022 Pr
at 17:43. wrote: I am attaching Adams' emais that were written at the same time I was being trafficked. Please note that Peter Mendelson met with Jeffery in January 07 the same month i met Ser ey Brin with nd Adam Casteltai!! Simone being my witnesses! Sent with proton Moil aeon email. On Monday.
Lames Fdw2rel_Soley In brief, our action concerns a letter which Mr Staley approved which said that (1) he did not have a close relationship with Mr Epstein and that (2) he was last in contact with Mr Epstein well before he joined Barclays. Our case is that both those statements were untrue and that M
oral of the story here is money doesn't make you happy. Maybe she can confess what happened to Carolyn? On Mon, Mar 31.2025 at 16:38, Hi President Tromp, Please can you follow up o aims. wrote: I seem to remember that her PR agent is the same as Monica Lewinsky's. I take it she wrote the message?
one 6 Packages 1 Waght 10 lbs. 0.9 hes Delvered Jun 10.203 09:37 Svc Ana Al Signed by A.CI.AJZ FecEx Use 1571645500717W Sender H K0.1 JE,, 41-Y ERSTI-IN Trampcnation Charge Discount Fuel Surcharge Reopen' RETURN GOODS NEIMAN MARCUS a. 9700 1= -0 97 ims 031 =, Total Transport
Zone 8 Package sent Iron: 33461 zp cede Tracking ID 837574511429 Sender Red MI Service Type Fedex 20ay J EPSTEIN Package Type FedEx Envelope JEFFREY E EPSTEIN Zone 8 Packages I Weniri 1.0 lbs. 0.5 kgs DOWNS Jun ID. 2003 1529 Trensponaton Charge 10.40 Svc Area 2R Dissent Signed by Fuel Surcharge 0.
Signed by FercEx Use 16015561001574f Sender J EPSTEIN JEFFREY E EPSTEIN Trantpataten Charge Disount
Resilient 52/5 528 1.66 0.c0 PATRICK OCHIN JEFFREY E EPSTE iN Transpartabon Charge DSCOure Fuel Sur
o des shpment Deleon: Based Pricing. Zone 5 Packets:teen, ken 33461 TO Cede 1st attempt Jun 07.2003 at 09:41 MI. Recipient not InbteIness cased. Tromp ID 637169384360 Service Type Facts Prienty Overnight Package Type Facts Emotes* Zone 5 Packages 1 Wright 1.0 be. 0.5 kga Delvered Jun 09.
etermine tamen: ht Cnel weigh. Trading ID 792328419909 Sender Recon Service Type FedEx mil Economy ALEX NDACHI Paciage Type Customer Packaging JEFFREY E. EPSTEIN C ISAJ3EU.A NDACHI BENDAG STATION Zone M 457 MADISON AVENUE P.O BOX 189 Ong..Dest JRBNBO 4TH FLOOR GILGIL NAKUVU KE Factsges 1 NEW YORK N
Page: 1 o15 Fades Tax ID: 71.0427007 JEFFREY E EPSTEIN 358 EBRELLO WAY PALM BEACH FL 33480 Invoice Qu
4.2081.6 Page: 1 o15 Fades Tax ID: 71.0427007 JEFFREY E EPSTEIN 358 EBRELLO WAY PALM BEACH FL 33480 In
my ALEX NDACHI Paciage Type Customer Packaging JEFFREY E. EPSTEIN C ISAJ3EU.A NDACHI BENDAG STATION Zone
e. My changes made are ref *clod n the invace amount. Discoum coped e me greater el volume discount or deport discount. No additional Decant apples Tromp to 834826441757 fl y Receive Service Type FedEx mil Priority DAVE RODGERS JEANNE BRENNAN Packege Type FedEx Pak JEFFREY E EPSTEIN FPIANCIAL
cogs. Dislance Based Prong. Regon 8 Release Ognecure on Ale. Tracking ig Sender Sanwa Two FedEx 2Day C FOLEY Package Type Customer Packaging JEFFREY E EPSTEIN Zone 8 457 MADISCN AVE Ames 1 NEW YORK NY 100224839 US Weigh tots, 1.4 Delivered Jun 15.2001 15:12 Transporlatice Charge Sonic* MONA Area Cod
JEFFREY E EPSTEIN 457 MADISON AVE NEW YORK NY 10022-6809
are rellecled in the invoice amount. Tromp ID 827487016562 Sender ROGOW Sergce Ttge Fedex 2Day BELLA Package Type FedEx Pak JEFFREY E EPSTEIN EPSTEIN INTERESTS gene 7 457 MADISON AVE 457 MADISON AVE 4Th FL Aeon 1 NEW YORK NY 100224809 US NEW YORK NY 10022 US Weighl 1.0 lbs. 0.5 kgs Deli
y S.ORIFFIN Bunt 0 000 Recioienl DAVO ROGERS JEFFREY E. EPSTEIN 457 MADISON AVENUE NEWYORK NY 10022 US
Distance Based PION. Regan 7 FedEx has audted this POW for correct coxes. n.ghl and service. Any changes made are rellecled in the invoice amount. Tromp ID 827487016562 Sender ROGOW Sergce Ttge Fedex 2Day BELLA Package Type FedEx Pak JEFFREY E EPSTEIN EPSTEIN INTERESTS gene 7 457 MADISON AV
M - 5EX f\BC.)Sky Rtt 5/22/22, 1.31 P J Epstein - Epstein a massage". She claims she was taken to his mansion, where he exposed himself and had sexual intercourse with her, and paid her $200 immediately af
e search of his. townhouse turned up evidence of sex trafficking and also found "hundreds — and perhaps thousands — of sexually suggestive U.S. v. Jeffrey Epstein photographs of fully partially — nude females". Some of the indictmena photos were confirmed as those of u_ nderage females. In a locked safe,
rhaps thousands — of sexually suggestive U.S. v. Jeffrey Epstein photographs of fully partially — nude
er the allegations .114§147112O1 Giuffre filed a defamation suit against Dershowitz, External video Where are they now? The pig99stpley9rp in t'ip Jeffrej pstein case (httpsjfiwww.yoytuhe.c. om/watch?v=yBn6reJqD Perversion of Justice, The Miami Herald, November 29, 2018. EFTA00265116 >ft. ‘.11CN C
IL i Fwctet mt..; Kw - m at iv JelirsY Epstein -Maps& Bloom asserted that the -woman had received:threats. The suit was tapped on November 4, am& Tromp anoney Alan Garter denied the allevatinns, -while Epstein declined to commentizatagrisaflial-60 -cp E cE CiArReE42. tristac PROF scicolt- teze
rcharge COJtel Pow', Charge Reagent ERIC CLAW J EPSTEIN NTERST 457 MADISON AVE 4TH FLOOR NEW YORK NY 10
Number: Page: 1 o18 Fedex Tax it) 71-0127007 JEFFREY E EPSTEIN 457 MADISON AVE NEW YORK NY 10022.6843
istance Based Pricing. Zone 2 Traciiing ID 828641901554 Sender Serece Type FedEx Standard CNernighl LARRY MORRISON Package Type FedEx Envelope JEFFREY E EPSTEIN Zone 2 457 MADISCN AVE Pieces 1 NEW YORK NY 100224843 US WNW 1.0 IDS. 0.5 kOS Delivered Aug 26.200211A2 Sews Area Code Al Signed by O.GONZAL
ipper Reference: NO REFERENCE INFORMATION FedEx rowel Use: 2420610I000208Q_ Fuel Surchercte • Fedex has MAW a Nei Distance Based Pricing. Zone 4 Tromp r0 837169385127 Service Type FedEx Priarty Overnighl Pacitage Type FedEx Envelope Zone 4 Pieces Weight Delivered Seneca Ana Code Signed by
Entities connected to both Jeffrey Epstein and Tromp

Lesley Groff
PERSON
Marc Rich
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
NEW YORK NY
LOCATION
Joi Ito
PERSON
Eric Trump
PERSON
Alan Dershowitz
PERSON
Ehud Barak
PERSON
George W. Bush
PERSON
Martin Nowak
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
JPMorgan Chase
ORGANIZATION
Condoleezza Rice
PERSONJack Goldberger
PERSON
Sarah Kellen
PERSON
Joe Biden
PERSON
Prince Charles
PERSON