Epstein Secrets

unseal it. We believe it to violate both the spirit and the most logical interpretation of the NPA, Chicago Hong Kong London Los Angeles Munich Palo Alto San Francisco Shanghai Washington O.C. Kag 19439748.2 EFTA00223578 07/29/2011 13:12 FAX Q1003/004 KIRKLAND & ELLIS LLP July 29, 2011 Page 2

wn Declaration, you stated that the NPA contained "an express confidentiality provision." In opposing the Motion to Unseal the NPA that was filed by Jane Doe, you stated that you had informed Judge Mama of the confidentiality provision during an earlier telephonic status conference occurring on August 14

ed calculation is also unsupportable under the applicable "clear and convincing evidence" standard. Chicago Hong Kong London Los Angeles %rich Palo Alto San Francisco Shanghai Washington. D.C. EFTA00312746 KIRKLAND & ELLIS LLP Jennifer Gaffney, Esq. and Patrick Egan, Esq. October 28, 2010 Page

g to recall, because I know she was going less and less to his residence. Q. Do you recal1writing in this table cause affidavit that events —that Jane Doe you that Ka relationship continued to escalate during the period she saw Mr. Epstein? A. Fri:intik beginning, yes. Q. And Ws fair to say that so

Commonsense Knowledge," Proceedings of the AAAI Spring Symposium on Acquiring (and Using) Linguistic (and World) Knowledge for Information Access, Palo Alto, CA, March 2002, American Association for Artificial Intelligence (2002). (24.) M. Minsky, The Society of Mind, Simon & Schuster, New York (1985).

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

96 Calvin College, The January Series, Grand Rapids, Michigan University of Calif, Davis, Neuroscience Colloquium Interval Research Corporation, Palo Alto Pacific Sociological Assn , Annual Meeting, Seattle John Hopkins Medical Institute/FMSF, San Diego Southwestern Psychological Association, Annual

Balancing with the players stacked against you. Applied Cognitive Psychology, 16, 365-366 (Book Review). Loftus, E.F. & Guyer, M. (2002) Who Abused Jane Doe?: The Hazards of the Single Case History. Skeptical Inquirer. Part I. Vol 26, #3 (May/June), Pp. 24-32. Loftus, E. F. & Guyer, M. J. (2002) Who Abu

anies and Selected Private and Government Organizations," Newport Beach, CA, April 26-28, 1999 MediaOne, Denver, CO, June 24-25, 1999 Ross Stores, Palo Alto, CA, July 8, 1999 PCS Health Systems, Scottsdale, AZ, July 16, 1999 Wellpoint, Thousand Oaks, CA, July 22-23, 1999 Corning, Inc., Corning, NY, Sep

k, New York) [2nd Circuit Opinion: 938 F.2d 1535 (2nd Cir. 1991)] Testified at deposition, 5/13/90 Testified in court (trial or hearing), 5/14/90 Jane Doe v. Stuart Brown. M.D. (San Diego, California) Testified by deposition, 6/6/90 Carin Evans vs. Richard Benton, Ph.D. (Houston, Texas) Testified at

Commonsense Knowledge," Proceedings of the AAAI Spring Symposium on Acquiring (and Using) Linguistic (and World) Knowledge for information Access, Palo Alto, CA, March 2002, American Association for Artificial Intelligence (2002). (24.) M. Minsky, The Society of Mind, Simon & Schuster, New York (1985).

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doc to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

unseal it. We believe it to violate both the spirit and the most logical interpretation of the NPA, Chicago Hong Kong London Los Angeles Munich Palo Alto San Francisco Shanghai Washington, D.C. K&E 19439748.1 EFTA00586200 KIRKLAND & ELLIS LLP A. Marie Villafana July 29, 2011 Page 2 paragraph 1

wn Declaration, you stated that the NPA contained "an express confidentiality provision." In opposing the Motion to Unseal the NPA that was filed by Jane Doe, you stated that you had informed Judge Marra of the confidentiality provision during an earlier telephonic status conference occurring on August 1

unseal it. We believe it to violate both the spirit and the most logical interpretation of the NPA, Chicago Hong Kong London Los Angeles Munich Palo Alto San Francisco Shanghai Washington D.C. K&E 19439748.2 EFTA00180295 07/29/2011 13:12 FAX la003/004 KIRKLAND & ELLIS LLP July 29, 2011 Page 2

Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLI

unseal it. We believe it to violate both the spirit and the most logical interpretation of the NPA, Chicago Hong Kong London Los Angeles Munich Palo Alto San Francisco Shanghai Washington D.C. K&E 19439748.2 EFTA00193948 EFTA00193949 07/29/2011 13: 12 FAX V1003/004 KIRKLAND & ELLIS LLP A. Mar

6, 09-80802, 09-81092, DECLARATION OF ADAM D. HOROWITZ 1. My name is Adam D. Horowitz. I am an attorney for Jane Doe No. 4. 2. The deposition of Jane Doe No. 4 was scheduled for September 16, 2009 at 1:00 p.m. at 350 Australian Ave. South, Suite 115, West Palm Beach, Florida. On the day before the de

unseal it. We believe it to violate both the spirit and the most logical interpretation of the NPA, Chicago Hong KOng London Los Angeles Munich Palo Alto San Francisco Shanghei Washington D.C. Ka2 19419748.2 EFTA00230790 07/29/2011 13: 12 FAX e 003/004 KIRKLAND & ELLIS LLP A. Vitiate& July 2

through his counsel, filed a "Motion to Dismiss the First Amended Complaint or, in the Alternative, for a More Definite Statement," in the matter of Jane Doe No. 101 v. Jay Epstein, Court File No. 09-CV-80591-ICAM. "Jane Doe No. 101" was on the list provided to Mr. Epstein's attorneys of individuals whom