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Entered on FLSD Docket 08/11/2009 Page 5 of 15 discussed Jeffrey Epstein with her in a public forum, l.e., Jane Doe 7 discussed her lawsuit with Haley Robson in public, with others. See Exhibit "A". Even so, an elementary review of the alleged questioning by the investigators as set forth in Jane Doe 7'
t. (Declaration, DE 251-2, 15). Moreover, Haley Robson's affidavit tells a different story; that is, Ja
Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaint/ff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Coun
the Plaintiffs/victims were threatened and harassed. 3. As with other Plaintiffs, Jane Does 4 and 7 were first introduced to Defendant Epstein by Hayley Robson, who was a high school friend.1 4. Robson had had contact with these Plaintiffs on several occasions in which she represented to Plaintiffs Jane D
d. 3. As with other Plaintiffs, Jane Does 4 and 7 were first introduced to Defendant Epstein by Hayley Robson, who was a high school friend.1 4. Robson had had contact with these Plaintiffs on several occasions in which she represented to Plaintiffs Jane Doe 4 and 7 that she is cooperating with Defe
Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Bradley James Edwards [email protected] Isidro Manuel Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell KEzell
, 48, 52, 56, 61, 65, and 69, Comp., DE I. Jane Doe 101 and 102 came to Defendant's home on a number of occasions. Jane Doe 101 brought her friend, Haley Robson (referenced by name in a number of actions) to experience this same "trauma" - it does not make sense. Jane Doe 101 had issues associated with law e
ccasions. Jane Doe 101 brought her friend, Haley Robson (referenced by name in a number of actions) to ex
Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Coun
limited without violating Epstein's constitutional due process rights to defend himself. 15. Next, Jane Doe #7 claims that investigators mentioned Haley Robson, but fails to state what references were made relative to Haley Robson. Is it Jane Doe #7's contention that investigators cannot ask others whether
ussed Jeffrey Epstein with her in a public forum, i.e., Jane Doe #7 discussed her lawsuit with Haley Robson in public, with others. See Exhibit "I", Robson Affidavit. Even so, an elementary review of the alleged questioning by the investigators as set forth in Jane Doe #7' s declaration shows that same
Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel/or Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Coun
ith inaccuracies and misstatements. For example, Haley Robson has not been asked to gather any information rela
case styled, Jane Doe v. Jeffrey Epstein, Haley Robson and Sarah Kellen, Case No. 502008CA006596XXXXMB A
@law.utah.edu Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street,
25. Susan Pope 26. 27. Subject matter: Counselor at Parent Child Center. Subject matter: Investigator. Subject matter: Investigator. 28. Haley Robson (Address unknown at this time) Subject matter various victims. Associate of Epstein who facilitated introductions with 29. Alfredo Rodriguez (
ator. Subject matter: Investigator. 28. Haley Robson (Address unknown at this time) Subject matter
0 Palm Beach Gardens, FL 33410 Tel: (561) 515-1400 Subject matter: Victim of Epstein. 6. Jane Doe (Case No.: 502008CA020614) do her attorney: Isidro M. Garcia, Esquire The Law Office of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, FL 33020 Tel: (954) 414-8033 Subject matter
Investigator. Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 Tel: (561) 838-5480 Subject matter: Investigator. 28. Haley Robson (Address unknown at this time) Subject matter: Associate of Epstein who facilitated introductions with various victims. 10 EFTA00221855 Case
-5480 Subject matter: Investigator. 28. Haley Robson (Address unknown at this time) Subject matter:
Palm Beach Gardens, FL 33410 Tel: (561) 515-1400 Subject matter: Victim of Epstein. 6. Jane Doe (Case No.: 502008CA020614) c/o her attorney: Isidro M. Garcia, Esquire The Law Office of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, FL 33020 Tel: (954) 414-8033 Subject matter
the Plaintiffs/victims were threatened and harassed. 3. As with other Plaintiffs, Jane Does 4 and 7 were first introduced to Defendant Epstein by Bayley Robson, who was a high school friend.' 4. Robson had had contact with these Plaintiffs on several occasions in which she represented to Plaintiffs Jane D
d. 3. As with other Plaintiffs, Jane Does 4 and 7 were first introduced to Defendant Epstein by Bayley Robson, who was a high school friend.' 4. Robson had had contact with these Plaintiffs on several occasions in which she represented to Plaintiffs Jane Doe 4 and 7 that she is cooperating with Defe
orida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Bradley James Edwards [email protected] Isidro Manuel Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected]
on as part of any claim or defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817 So.
nsel for Plaintiff in Related Case No. 08- 08804 Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street,
Entities connected to both Haley Robson and Isidro Manuel Garcia

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Adam D. Horowitz
PERSONJack Patrick Hill
PERSONRichard Horace Willits
PERSONMichael J. Pike
PERSONRobert D. Critton
PERSONKatherine W. Ezell
PERSONRobert C. Josefsberg
PERSON
Alan Dershowitz
PERSON
Sarah Kellen
PERSONMermelstein & Horowitz
ORGANIZATION
Salt Lake City
LOCATIONJack Scarola
PERSONBruce E. Reinhart
PERSONSouthern District
LOCATION
Lake Worth
LOCATION