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privacy. 5. This is strictly a "fishing expedition" unrelated to any aspect of this case. A similar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A copy of the objection to the Notice is attached as Exhibit "B" and Judge Garr
BOARD CERTIFIED CVO-TRIAL LAWYER Sent by Fax and U.S. Mail Isidro M. Garcia, Esq. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmukumALINVBSTIOMOR BARBARA M. NkKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALE
kKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL Dear Sid: Please be informed thal subpoenaed deposition in thel.L. Epstein case on April 16th, 2009 is hereby cancelled. Cordially Robert D. Critton, Jr. RDC/clz cc: Jack A. Goldberger, Esq. L•A•W•Y•E •R•S TELEPHONE
py of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, a
ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,
ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,
OW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pur
et al Case No. 50 2008CA025120)COVMB Amended Notice of Production from Non-Party Page 3 COUNSEL LIST ire Phone: Attorneys for Jeffrey Epstein Robert Griffon, Esquire Bu Pho Fax: Attorneys for Jeffrey Epstein EFTA00722718 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEAC
22 23 24 25 1 2 3 4 5 6' 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Fifth. Q Aren't your observations with Jeffrey Epstein's interactions with E.W., wouldn't you agree he coerced her into a life of prostitution? MR. YAREMA: Object to the form. A Fifth. Q And based on yo
East 66th Street? 16 Q Flow is it that you have supported 17 A The Fifth. 17 yourself financially, since you have been in this 18 Q When Mr. Epstein was incarcerated in 18 country? 19 jail, you went to visit him on numerous 19 MR. YAREMA: Object to the fonn. 20 occasions; is that correct?
rivileges, I'm objecting on privacy grounds. 1 Epstein's sex slaves? 2 MR. YAREMA: Object to the Iona 3 A Fifth. 4 Q What does it mean to be Jeffrey 5 Epstein's sex slave? 6 MR. YAREMA: Object to the form. 7 A Fifth. 8 Q Are you aware that Jeffrey Epstein reads 9 books on how to be a pro
al acts with him inside his bedroom? MR. YAREMA: Object to the form. A Fifth. Q Isn't it true that after an underage minor female was brought to Jeffrey F.pstein's house, typically or Adriana or yourself would lead that underage minor female to Jeffrey Epstein's bedroom and leave them alone in the room; is
plane on numerous occasions, correct? MR. YAREMA: Object to the form. A Fifth. Q On September 22,2003, you were listed as being on a flight with Ma Jeffrey 0 Epstein, S.H. and B.T. My question is who is S.H. and who is B.T.? MR. YAREMA: Object to the font. A Fifth. Q Do you know A Fifth. 51 1 Q Prior to t
ancially, since you have been in this 18 Q When Mr. Epstein was incarcerated in 18 country? 19 jail, you
g to tome to Jeffrey Epstein's home for sexual activity? MR. YAREMA: Object to the form. A Fifth. (Whereupon, at this point in the proceedings, Robert Griffon left the deposition room.) Q Did Jeffrey Epstein instruct you to call A.C. to come to his home and give him a massage 1 2 3 4 5 6 7 8 10
09 Robert Griffon, Esquire Burman, °Fitton, Luther & Coleman - WPB 903 Banyan Boulevard SAO 400 West Palm Beech, FL 33401 Re: Jam Doe No. 2 vs. Jeffrey Epstein 9-18-09 Scheduled Deposition of Jane Doe No. 4 Statement for Record Description of Services Repo App HT- 1st Hr Appearance 1 st Hr Depo Trans 0
N BLVD SUITE 400 West PALM BEACH, FL 33401 Dec. Can / References Invoice 9/17/20091 28616 Data Number Terms Due on receipt 2ANII DOE as v EPSTEIN Sam/ • Rendered ANIONS 9/16/2009 VIDEOTAPED DEPOSITION OP: JANE DOE I 4 Tech Time • 1ST 2 Hours 275.00 ocitai Tape S c toS 1 15.00 MASTER TA
West Palm Beech, FL 33401 Re: Jam Doe No. 2 vs. Jeffrey Epstein 9-18-09 Scheduled Deposition of Jane Doe
Avenue, Suite 1600 West Palm Beach, Florida 33401 (601) 832-7600 Phone (681) 832-7508 Fax Tax ID: 28-3892W www.proseortoofn September 17, 2009 Robert Griffon, Esquire Burman, °Fitton, Luther & Coleman - WPB 903 Banyan Boulevard SAO 400 West Palm Beech, FL 33401 Re: Jam Doe No. 2 vs. Jeffrey Epstein 9
Entities connected to both Jeffrey Epstein and Robert Griffon

Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
West Palm Beach
LOCATIONSpencer Kuvin
PERSONGoldberger & Weiss
ORGANIZATIONDonald W. Hafele
PERSON