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E-mail and U.S. Mail Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Re: Doe v. E_pstein L.M. v. Epstein E.W. v. Epstein Dear Brad: A L!MlHD LIABILITY PARTNERSH IP August27,2009 AbELO!)I ). BENAVENTE P"RAI.EGAI./INVESTIGATOR ) ES
pending motion for a protective order filed by Jane Does 2-8.1 Jane Doe supplements those facts with the following facts. 2. On June 30, 2008, Jeffrey Epstein pled guilty to one count of procuring a person under 18 for prostitution and one count of felony solicitation to prostitution before the Circuit Co
119-MARRA/JOHNSON 4 Please be advised that Mr. Epstein plans to be in attendance at the deposition of y
rder (Case No. 08-CV-80119, dkt. #292) preventing defendant Epstein from attending her upcoming deposition and suppl
th the following facts. 2. On June 30, 2008, Jeffrey Epstein pled guilty to one count of procuring a
ach County, Florida. He was sentenced to 18 months in jail. 3. In the course of the plea/sentencing colloquy, Palm Beach Circuit Court Judge Deborah Dale Pucillio explicitly instructed Defendant as follows: Court: Okay. [Item] D is, you shall not have any contact with the victim, . . [is] there more than on
uite 1650 Fort Lauderdale, FL 33301 Re: Doe v. E_pstein L.M. v. Epstein E.W. v. Epstein Dear Brad: A
th the following facts. 2. On June 30, 2008, Jeffrey Epstein pled guilty to one count of procuring a person u
119-MARRA/JOHNSON 4 Please be advised that Mr. Epstein plans to be in attendance at the deposition of y
rder (Case No. 08-CV-80119, dkt. #292) preventing defendant Epstein from attending her upcoming deposition and suppl
th the following facts. 2. On June 30, 2008, Jeffrey Epstein pled guilty to one count of procuring a
tencing colloquy, Palm Beach Circuit Court Judge Deborah Dale Pucillio explicitly instructed Defendant as follows: Cour
or Sanctions and Motion for Protective Order and Incorporated Memorandum of Law, and states as follows: 1. By now, this Court is familiar with Jeffrey Epstein’s practice of intimidating and harassing his victims, as well as the Plaintiffs’ level of fear of Jeffrey Epstein. See, e.g. Plaintiffs Jane Doe No.
the parties, appropriate sanctions and other relief are necessary to compensate Plaintiff Jane Doe No. 4 and prevent future misconduct by Defendant Epstein. WHEREFORE, Plaintiff, Jane Doe No. 4, respectfully requests (1) an award of sanctions, including attorneys’ fees and costs reasonably and necessa
f Jane Doe No. 4 and prevent future misconduct by Defendant Epstein. WHEREFORE, Plaintiff, Jane Doe No. 4, respectf
ows: 1. By now, this Court is familiar with Jeffrey Epstein’s practice of intimidating and harassing
with the Plaintiffs. (D.E. 238). 8. The July 31, 2009 Order mirrored the June 30, 2008 criminal sentence entered by Palm Beach Circuit Court Judge Deborah Dale Pucillio, wherein she instructed Jeffrey Epstein that he shall have “no direct or indirect contact” with the Plaintiffs. (D.E. 238) 9. There can be no doub
have previously brought to this Court’s attention Jeffrey Epstein’s pattern of intimidating and harassing his victims
er, dated October 23, 2009 (D.E. 369) (forbidding Epstein from attending Jane Doe No. 4’s deposition); Omn
position. 3. Yet again, on November 24, 2009, Defendant Epstein flagrantly violated multiple Orders of this Cour
have previously brought to this Court’s attention Jeffrey Epstein’s pattern of intimidating and harassing
ntence entered by Palm Beach Circuit Court Judge Deborah Dale Pucillio, wherein she instructed Jeffrey Epstein that he
Entities connected to both Jeffrey Epstein and Deborah Dale Pucillio

Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSON
Paul Cassell
PERSONScott Rothstein
PERSONRobert D. Critton
PERSONRobert C. Josefsberg
PERSONMichael J. Pike
PERSON
Adam D. Horowitz
PERSON
Salt Lake City
LOCATIONKatherine W. Ezell
PERSONRichard Horace Willits
PERSON
United States District Court
ORGANIZATIONJack Patrick Hill
PERSONIsidro Manuel Garcia
PERSONStuart S. Mermelstein
PERSONMermelstein & Horowitz
ORGANIZATIONRothstein Rosenfeldt Adler
ORGANIZATION