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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
Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424
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
rt 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 MPike@bclclaw.
, 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
Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08- 80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424
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
Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424
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
isid [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart Shipley
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
laim or defenses, unless solely for impeachment, identifying the subjects of the information: 1. C.M.A. do her attorneys: Jack Scarola, Esq. and Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Tel: (561) 686-6300 Richard Will
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
pa.com 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] Paul G. Cassell [email protected] Ric
on as part of any claim or defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817 So.
- 80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley,
Entities connected to both Haley Robson and Jack Patrick Hill

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONRichard Horace Willits
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Adam D. Horowitz
PERSONIsidro Manuel Garcia
PERSONMichael J. Pike
PERSONRobert D. Critton
PERSONKatherine W. Ezell
PERSON
Alan Dershowitz
PERSONRobert C. Josefsberg
PERSON
Sarah Kellen
PERSONJack Scarola
PERSONBruce E. Reinhart
PERSON
Lake Worth
LOCATION
Kenneth Marra
PERSON
Scarlett Johansson
PERSONSouthern District
LOCATION