Epstein Secrets

1. Depo of Dr. Agresti and Kathy Sloan 2. Depo of Lisa and Thomas Moreland 3. Depo of Cody Moreland (assaulted 4. Records from Dr. Reed. 5. Kliman — report and depo EFTA_R1_00012600 EFTA01734429 March 2, 2010 JANE DOE 3- DOB- TRIAL DATE: DISCOVERY CUTOFF: 4112/10 • Immediate Issues: 1.

t do? 3. 4. 5. • Future Issues 1. Hire Shawn Michael (legal scrubber) to examine bills (Cost?; contingency/hourly) 2. Expert (Ed Blumenthal — Coleman's friend — former Fla. Bar president; plaintiffs attorney — great credentials; Miami atty.?) 3. 4. 5. • Discovery to do/outstandinq (to and from

n can that circumstance be addressed by a motion such as the instant one.) 11. Next, Plaintiffs, Jane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection filed to date. This also includes the two most recent motions, which attempt to prevent Defendant's

dant's motion is hereby GRANTED: Plaintiff shall pay sanctions in the amount of in costs and $ in fees directly to Burman, Clifton, Luther and Coleman within 10 days, and further directs that the Plaintiff make herself available for deposition no later than October , 2009 beginning at 9:30 am. at

n can that circumstance be addressed by a motion such as the instant one.) 11. Next, Plaintiffs, Jane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection filed to date. This also includes the two most recent motions, which attempt to prevent Defendant's

dant's motion is hereby GRANTED: Plaintiff shall pay sanctions in the amount of in costs and $ in fees directly to Burman, Clifton, Luther and Coleman within 10 days, and further directs that the Plaintiff make herself available for deposition no later than October , 2009 beginning at 9:30 am. at