Document DOJ-COURT-278 is a legal document filed in the United States District Court for the Southern District of Florida in connection with the case JANE DOE NO. 2 vs. JEFFREY EPSTEIN.
The document, entered on the docket on August 20, 2009, outlines an agreement between Jeffrey Epstein and Carolyn Margaret Andriano regarding an Independent Medical Examination (IME) of the plaintiff. It addresses the plaintiff's request to have a third-party present at the IME, with an agreement reached to provide a video feed to a separate room where the plaintiff's agent can monitor the examination.
Case 9:08-cv-80119-KAM Document 278 Entered on FLSD Docket 08/20/2009
Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 I I ---------------- Defendant, Jeffrey Epstein and Plaintiff, Carolyn Margaret Andriano, File This Notice of Agreement Relative to Defendant's Emergency Motion For Independent Medical Examination Of Plaintiff, Plaintiff's Response In Opposition and Defendant's Reply Thereto Defendant, JEFFREY EPSTEIN (hereinafter "EPSTEIN") and Plaintiff, CAROLYN MARGARET ANDRIANO ("Plaintiff' or "CMA"), File This Notice of Agreement Relative to Defendant's Emergency Motion For Independent Examination Of Plaintiff, Plaintiff's Response In Opposition and Defendant's Reply Thereto: 1. On July 29, 2009, Defendant filed the Emergency Motion for IME of Plaintiff (DE 245). 2. On August 7, 2009, Plaintiff filed her Response In Opposition and Incorporated Motion for Protective Order Regarding Defendant's Emergency Motion For IME (DE 254). 3. On August 17, 2009, Defendant filed his Reply thereto (DE 273). Case 9:08-cv-80119-KAM Document 278 Entered on FLSD Docket 08/20/2009
Page 2 of 4 4. While several issues remain outstanding and require the court's attention relative to the above docket entries, the undersigned attorneys have reached an agreement relative to Plaintiffs specific request to have a third-party present at said IME. In particular, the undersigned attorneys have agreed that Plaintiff will be provided a television monitor in a separate room accompanied by a video feed, thereby allowing Plaintiffs agent to monitor the IME from a location separate and apart from where the IME is being performed. Such an agreement was reached as a result of Defendant's expert, Dr. Hall, offering same in his Affidavit and the undersigned attorneys' agreement to same. 5. The Defendant will be responsible for the costs associated with providing the television monitor and the video feed. 6. In light of the foregoing agreement, the court is now relieved from having to rule on those portions of the Emergency Motion, the Response in Opposition and Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 1Ll day of t1J,t/ . , 2009 Case 9:08-cv-80119-KAM Document 278 Entered on FLSD Docket 08/20/2009
Page 3 of 4 ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax (Counsel for Defendant Jeffrey Epstein) Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 3 3160 305-931-2200 Fax:305-931-0877 [email protected] [email protected] Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lalce Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 [email protected] Counsel for Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. ProHac 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 Case 9:08-cv-80119-KAM Document 278 Entered on FLSD Docket 08/20/2009








