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2 Protective Order as to Jeffrey Epstein’s Attendance at Deposition of Plaintiffs, and Incorporated Memorandum of Law (D.E. 292); Affidavit of Dr. Kliman (D.E. 223, Exh. A). 2. On September 16, 2009, Jeffrey Epstein’s conduct reached a new low when he recklessly violated (i) this Court’s No-Contact
o “direct or indirect contact” 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. 23
th a message of any sort from you, is that clear? 1 Jane Doe’s 2-8 have filed an affidavit of Dr. Kliman attesting to the psychological harm that they will suffer if Epstein is allowed to intimidate them by attending their deposition. Jane Doe is prep
icial Circuit in and for Palm Beach 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,
ane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection
fendant's state plea conference of June 30, 2009, Palm Beach Circuit Court Judge Deborah Dale Pucillio explicitly instructe
1 Jane Doe’s 2-8 have filed an affidavit of Dr. Kliman attesting to the psychological harm that they wi
. In the course of the plea/sentencing colloquy, Palm Beach Circuit Court Judge Deborah Dale Pucillio explicitly instructe
Entities connected to both Kliman and Palm Beach Circuit Court

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONMichael J. Pike
PERSON
Adam D. Horowitz
PERSONRichard Horace Willits
PERSONRobert C. Josefsberg
PERSONJack Patrick Hill
PERSONKatherine W. Ezell
PERSON
George W. Bush
PERSONIsidro Manuel Garcia
PERSONRobert D. Critton
PERSONScott Rothstein
PERSONStuart S. Mermelstein
PERSONJack Scarola
PERSONMermelstein & Horowitz
ORGANIZATIONBruce E. Reinhart
PERSON