Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 1 of 18 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON ______________ __:! 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 ______________ __:! DEFENDANT'S REPLY TO PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL, WITH INCORPORATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Reply To Plaintiff's Response To Defendant's Motion For Reconsideration And/Or Request For Rule 4 Review And Appeal, With Incorporated Memorandum Of Law. 1 In support, Epstein states: I. The Requests For Production, Argument And Memorandum Of Law a. Request Number 7, 9 and 10 (i) Plaintiff Limited the Scope of the Requests In Her Reply Plaintiff is not only chameleon like in her Response in Opposition to the Motion For Reconsideration And/Or Rule 4 Appeal ("Response to the Rule 4 Appeal") but her arguments simply parrot back the Magistrate's Order at DE 462 without addressing the substantive arguments made by Epstein. 1 Epstein reincorporates his arguments set out in his initial Rule 4 Appeal. Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 2 of 18 Doe v. Epstein 08-CV80119 Page No. 2 First, Plaintiffs arguments in the Response to the Rule 4 Appeal change color as her covert strategy seems to fade. For instance, it was Plaintiff in her Reply to the Response in Opposition to her Motion to Compel (the "Reply to the Motion to Compel")(DE 354, p.3) that further defined or limited for the court exactly what Plaintiff expected to receive in response to request numbers 7, 9 and 10. Plaintiff stated in no uncertain terms that "[t]hese requests simply seek information that the federal government gave to Epstein .... " DE 354, p.3. Before this specious limitation was made by Plaintiff, Epstein argued in his response in opposition (DE 339, p.7-8) that these requests are the same type requests the court found subject to the Fifth Amendment. (DE 464) With the limitation made by Plaintiff and her counsel in the Reply, the court ruled "[t]hat the earlier requests referenced by Epstein were significantly broader than the narrow requests at issue here, including for example, a request for all documents 'relating to' the federal non-prosecution agreement, and all documents 'relating to' either the federal or state criminal investigations. These requests would have required Epstein to pick and choose which documents were responsive and in this way force Epstein to use to effectively make 'use of the content his mind,' an action that would undeniably implicate the Fifth Amendment." (DE 462, p.9) Clearly the instant requests (as Plaintiff now defines them) are exactly the same type of broad requests this court has already ruled upon. See Response in Opposition (DE 339) Had the Plaintiff not limited the scope of the requests in her Reply (DE 354, p.3), the court would not have labeled these requests as "narrow" because these requests now seek all information related to the federal non-prosecution agreement and all documents relating to either the federal or state criminal investigations, which clearly require Epstein to effectively make use of the content his mind to determine what is and what is not responsive to these broad requests. Simply put, Plaintiff is flip-flopping her arguments. Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 3 of 18 Doe v. Epstein 08-CV80119 Page No. 3 As a result of the limitation made by Plaintiff in her Reply and as a result of this court's Order (DE 462), Epstein responded - "[a]s to Request Number 7, Epstein and his attorneys do not have any "discovery information" provided to them by the federal government and [ a]s to Request Number 9, Epstein has not been given any evidentiary materials or evidentiary documents by the federal government." (DE 477) Certainly, these responses were not intended to "gild the lily" as Plaintiff contends. The responses were made based upon Plaintiffs limitation in what she sought from Epstein and because this court entered an Order based upon that limitation. Had the limitation not been made, neither this court nor Epstein would have been misled down this primrose path. Nonetheless, Plaintiff now seeks to obtain the full breadth of information sought under request numbers 7, 9 and 10. However, that argument shall meet a short death in that Plaintiff herself limited the scope of the requests in her Reply and failed to timely file her own Rule 4 Appeal after the court entered its order at DE 462, which adopted Plaintiff's limited scope of the requests (which Plaintiff now wishes to change). See S.D. Fla., Rule 4(a)(l), Mag. J. 2009. If the court made a mistake in adopting the limited scope of the requests (which it did not), Plaintiff should have timely appealed. Instead, Plaintiff now attempts to backdoor a Rule 4 Appeal in her Response In Opposition to Defendant's Rule 4 Appeal. Again, if Plaintiff believed that this court improperly interpreted her limitation of the requests set out in her reply motion, Plaintiff had the obligation to timely file an appeal, which she did not. As such, Plaintiffs requested relief in this regard should be denied. (ii) Mr. Edwards Already Has the Information He Seeks Pursuant to this Improper Motion Practice Several depositions have occurred over the last 4 weeks wherein it appears Mr. Edwards already has the information he seeks responsive to these requests, which is likely the reason Mr. Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 4 of 18 Doe v. Epstein 08-CV80119 Page No. 4 Edwards has not filed any affidavits supporting the specious arguments set forth in Plaintiffs Motions. As such, there is no substance or factual representations made by Plaintiff to support her argument. Plaintiff is wasting attorney time and judicial resources in her effort to obtain what she already has in her possession. For example, at a deposition of Mr. Epstein on February 17, 2010, the following exchange occurred: Mr. Edwards: The 87-page Palm Beach Police Department incident report where there are numerous underage females describing their interaction with Mr. Epstein at his house. I'm specifically reading from page 41 related to A.H., who was one of the victims he pied guilty to. Mr. Pike: Is that the same document that you're seeking production of, in this same exact case? Mr. Edwards: I don't know what you're talking about. This is something from the state attorneys' file. It is clear from Mr. Edwards's response above (attached as Exhibit "A") that he has the information from the Palm Beach Police Department and the information from the State Attorneys' file. This begs the question - if plaintiff already has the information she seeks, why is Plaintiff wasting valuable attorney time and judicial resources to obtain what is already in hand? At the deposition of AR on March 15, 2010, the following exchange occurred: Mr. Edwards: Well, at some point in time what's been marked as defense Exhibit "l", you received a grand jury investigation target letter, correct? *** Mr. Edwards: There's another message from 9/11/05 saying "I got a car for," and then the name is blotted out. The State Attorneys' Office blotted the names of minors out sometimes in their file .... *** Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 5 of 18 Doe v. Epstein 08-CVS0l 19 Page No. 5 Once again, Mr. Edwards's response above (attached as Exhibit "B") establishes that he has the information from both the Palm Beach Police Department and the State Attorneys' file. In fact, as argned infra, Mr. Edwards has certain info1mation from the Palm Beach Police Department, which resulted from various alleged "trash pulls" from a residence on Palm Beach (e.g., certain notepads). Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on March 19, 2010, the following exchange occmTed: Mr. Kuvin: Okay. And what were the dates of the surveillance? Witness: [Referencing his Report] It appears she met with members of the B.S.F. unit, Burglary Strike Force .... *** Mr. Knvin: [Referencing the Report] Ifwe go down to page 40 in your report, first let me back up .... Mr. Kuvin: Okay. So the chain of custody which we have marked as Exhibit 5 shows that all the evidence you had in this case was given to the FBI. ... *** The undersigned was at Detective Recarey's deposition, copies of which are attached as Exhibit "C". Mr. Kuvin and Mr. Edwards had copies of various reports and also had copies of various message pads claimed to be "pulled" from Epstein's trash by the Palm Beach Police Department. It is clear from these deposition transcripts that opposing counsel has information from the Palm Beach Police Department and the State Attorneys' file. See also, infra for additional argument. (iii) Work-Product- Palm Beach State Attorneys' File Next, as to any information obtained from the State Attorney at any phase, the State Attorney has not provided anything to Epstein or his attorneys. While the State Attorneys' file Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 6 of 18 Doe v. Epstein 08-CV80119 Page No. 6 was made available for inspection, Jack Goldberger, Epstein's criminal lawyer, went over to the State Attorneys' Office and hand selected information from the file for copying, including certain witness interviews. See Exhibit "D," Affidavit of Jack Goldberger. Accordingly, the information hand selected by Mr. Goldberger falls under the work-product doctrine as production of same would reveal Mr. Goldberger's mental impressions, thought processes and strategy relative to the defense of Epstein. Smith v. Florida Power & Light Company, 632 So.2d 696, 698 (Fla. 3rd DCA 1994)(even if individual documents are not work-product, "the selection process itself represents defense counsel's mental impressions and legal opinions as to how the evidence in the documents relates to the issues and the defenses in the litigation"). Id. The information simply falls under the "highly protected category of opinion work-product." Id; see also Fla.R.Civ.Pro. 1.280. Also, Counsel for Jane Does 2-8 in the Federal companion cases apparently obtained a copy of the file retained by the Palm Beach State Attorneys' Office. How did Mr. Horowitz obtain the file? Did Mr. Horowitz obtain the records by virtue of a Chapter 119 request or a Freedom of Information Act Request? Certainly, Mr. Edwards is able make such public records requests or can subpoena the requested information, neither of which would implicate the work product privilege as outlined above. Here, the standard is a showing of a need to obtain the information, and the inability to obtain the substantial equivalent without undue hardship. Metric Engineering, Inc. v. Small, 861 So. 2d 1248, 1250 (Fla. 1st DCA 2003)(To show 'need,' a party must present testimony or evidence demonstrating the material requested is critical to the theory of the requestor's case, or to some significant aspect of the case); Ashemimry v. Ba Nafa, 847 So.2d 603 (Fla. 5th DCA 2003). In addition, Florida Rule of Civil Procedure l.280(b)(3). does allow discovery of fact Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 7 of 18 Doe v. Epstein 08-CV80119 Page No. 7 work product where the requesting party can show need and the inability to obtain the substantial equivalent by other means without undue hardship. Vesta Fire Ins. Corp. v. Figueroa, 821 So.2d 1233, 1234 (Fla. 5th DCA 2002)(the showing of need and undue hardship necessary to overcome the work product immunity must include specific explanations and reasons). Again, Mr. Edwards fails to submit any affidavit or any other docnment meeting the above criteria. Additionally, this court should consider placing the Palm Beach State Attorney and the USAO on Notice that their investigative files are being requested. Since Plaintiff seeks information given by federal government and the state attorney to Epstein, including correspondence, Epstein reincorporates the argnments setout in his initial Rule 4 Appeal as that information is within the penumbra of the protections of Federal Rules of Evidence 408 and 410. Moreover, despite Plaintiffs contention, Federal Rule of Evidence 410 is applicable because negotiations did not end with a federal plea. Furthermore, Federal Rule of Evidence 408 is applicable given that 18 U.S.C. 2255 is quasi-civil remedy. Clearly, the infonnation sought by Plaintiff has no evidentiary value - given that Plaintiffs have the raw materials and police reports and affidavits resulting from state investigation. Accordingly, there is a chance that the Palm Beach State Attorney and the USAO may not want to disclose their files for one reason or another. Based upon the foregoing and based upon the arguments made in Epstein initial Rule 4 Appeal, Epstein's Fifth Amendment Privilege as it relates to the above requests should be sustained and Plaintiffs Motion requested relief should be denied as untimely. To the extent this court overrules Epstein's Fifth Amendment Privilege, this court should order an in camera inspection (as requested in the Rule 4 Appeal) to determine what information, if any, is work- product and thus subject to Federal Rule of Evidence 502. Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 8 of 18 Doe v. Epstein 08-CV80119 Page No. 8 b. Request Numbers 12 and 13 As set forth in more detail in DE 282 and 283 (which were provided to the court in camera) and in Epstein's Rule 4 Appeal, Epstein cannot provide answers/responses to questions relating to his financial history and condition without waiving his Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution, which includes his tax returns. An elementary review of Plaintiff's Response In Opposition to the Rule 4 Appeal (DE 485) clearly shows that the information Plaintiff seeks may provide a link in the chain of evidence and thus presents a real and substantial danger of self-incrimination in this case, in other related cases and as well in areas that could result in criminal prosecution. First, Plaintiff claims to require the tax returns to advance her theory that ". . .Epstein used his wealth and power to lure economically disadvantaged minor girls to his homes in palm Beach, New York and St. Thomas where they were sexually assaulted." (the "First Theory")(DE 485, p.18) Second, without attaching any affidavits, Plaintiff claims that" ... Epstein is moving all of his assets overseas in an effort to defeat collection of any judgment that Jane Doe and other plaintiffs may obtain." (DE 485, p.l 9)(the "Second Theory"); see also fn. 5 therein. Third, Plaintiff claims she has limited evidence (although she does not attach same or provide it in camera) proving that Epstein is using "modeling agencies" to lure underage girls to him for sexual purposes, and that his tax returns may reveal the existence and location of such modeling agencies (the "Third Theory"). Finally, Plaintiff's Fourth theory is that the tax returns may provide a link in the chain of evidence used to establish a nexus to Epstein's alleged offenses under 18 U.S.C. 2255 (the "Fourth Theory"). Plaintiff's admissions here are fatal, and furthermore require Epstein to produce information that is tantamount to Epstein being a witness against himself or incriminating himself. Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 9 of 18 Doe v. Epstein 08-CV80119 Page No. 9 Again, to the extent that the Comt determines that the tax retnrns are relevant and that there is a compelling need for at least their disclosure of Epstein's wealth for punitive damage purposes, Epstein would agree to stipulate, through his attorneys, that he has a net wmth of over $50,000,000. Such a stipulation more than satisfies any necessity for the disclosure of the tax returns or any additional net worth information. (i) Plaintiffs First Theory Is Fatal To Request Numbers 12 and 13 Based upon the above admissions, it is clear that Plaintiff now seeks information that may provide a link in the chain of evidence used to prosecute Epstein. As a result, DEs 282 and 283 (in camera), other related Orders and the Order at DE 480 must be analyzed to reach the correct legal conclusion. With regard to Plaintiffs First Theory, the court must be cognizant of the allegations in the related cases regarding sexual misconduct with and abuse, exploitation, and sexual battery of alleged minors. Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 10 of 18 Doe v. Epstein 08-CV80119 Page No. 10 2 See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4th DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth Amendment - "[i]t would be incongruous to have different standards determine the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d § 1280 Effect of Failure to Deny - Privilege Against Sel.f-lncrimination (" ... court must treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24 Fla.Jur.2d Evidence §592. D~fendants in civil actions. - " ... a civil defendant who raises an affirmative defense is not precluded from asserting the privilege [against self-incrimination], because affirmative defenses do not constitute the kind of voluntary application for affirmative relief' which would prevent a plaintiff bringing a claim seeking affirmative relief from asse1ting the privilege. Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 11 of 18 Doe v. Epstein 08-CV80119 Page No. 11 Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 12 of 18 Doe v. Epstein 08-CVS0 119 Page No. 12 Accordingly, it is clear that Plaintiff and her counsel seek this information not to further their civil case, but to gain information to aid in the future prosecution of Epstein in direct violation of his Fifth Amendment rights. In fact, the Mermelstein and Horowitz firm was quoted in the Palm Beach Post stating, among other things, that the book sold to undercover agents could open the door to future prosecution of Epstein. As such, Plaintiffs' counsels' intention is clear-to use the civil discovery process to attempt to further prosecute Epstein. See Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 13 of 18 Doe v. Epstein 08-CV80119 Page No. 13 http ://j essicaarbour.blogspot.com/2010/03/horowitz-discusses-possibility-of.html. According! y, Epstein's 5th Amendment rights in this regard should be sustained. (ii) Plaintiffs Second Theory Is Fatal To Request No. 12 Plaintiff claims that " ... Epstein is moving all of his assets overseas in an effort to defeat collection of any judgment that Jane Doe and other plaintiffs may obtain" and, as a result, his tax returns may help to provide such affirmative evidence. (DE 485, p.19). As the court previously ruled, "[a]part from Defendant's justified concerns regarding waiver, are the very real concerns that by forcing Defendant to respond to the subject discovery requests regarding his financial status and history, the Court risks providing the government with a link in the chain of evidence needed to convict Defendant of a crime. The potential for providing such a 'link' is high when one considers that by forcing Defendant to respond, he will be implicitly communicating statements of fact, authenticating documents and testifying to their location, as well as providing clues as to the identity and location of witnesses that by such disclosure may serve to further a criminal investigation against him." (DE 480) Further, the instant requests here would require disclosure in connection with Defendant's ownership of assets and transfers of assets inside and outside the United States, such disclosure could reveal the availability to him and/or use by him of interstate facilities, which again may implicate Defendant in additional crimes. See also DE480 for the same reasoning. In short, like the requests outline in DE 480, the requests here " ... seek to have Defendant be a witness against himself, assist the Plaintiffs' investigation and identify areas that could result in future prosecution of Defendant, a result clearly prohibited by the Constitution." DE 480 See Rudy- Glanzer v. Glanzer, 232 F.3d at 1263 (the "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of prosecution and also covers those circumstances Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 14 of 18 Doe v. Epstein 08-CV80119 Page No. 14 where the disclosures would not be directly incriminating, but could provide an indirect link to incriminating evidence). Accordingly, the court at DE 480 sustained Epstein's Fifth Amendment Privilege as it related to each of the subject net worth/asset discovery requests. Since the tax returns could result in the production of the same asset/net worth information, the requests are subject to the Fifth Amendment and, thus, this court should sustain Epstein's Fifth Amendment privilege. (iii) Plaintifrs Third Theory Is Fatal To Request Numbers 12 and 13 Under Plaintiffs Third Theory, she claims Epstein's tax returns may reveal the existence and location of modeling agencies Epstein uses to lure underage girls to him for sexual purposes. (E 485) These issues have been addressed at DE 293. In particular, this court sustained Epstein's objections to producing information regarding " ... MC2 models or Jean Luc Brunel relating or referring to females coming into the United States from other countries .... [because it] could reveal the availability to him of and/or use by him of interstate facilities .... " DE 293, p.6. In making such a ruling, the court recognized much of the argument set out above and herein including, but not limited to, various federal and state criminal statutes claimed to have been violated by Epstein (i.e., 18 U.S.C. 2422(b) and 18 U.S.C. 2423(b)), argument for which was provided in camera and considered by this court. See M·, DE 242 and 293. While the govermnent (i.e., the IRS) may have Epstein's tax returns and passport in some form or another, it does not have information that may corroborate Plaintiffs' claims of travel in interstate commerce, use of interstate facilities to commit crimes and/or violations of various federal and state criminal statutes. Given the recent news reports regarding the potential for Epstein to be re-indicted due the alleged finding of the "black book," responding to request numbers 12 and 13 may provide a link in the chain of evidence and, thus, presents a real and Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 15 of 18 Doe v. Epstein 08-CV80119 Page No. 15 substantial danger of self-incrimination in this case, in other related cases and as well in areas that could result in criminal prosecution. Accordingly, this court should sustain Epstein's Fifth Amendment privilege as to request numbers 12 and 13. (iv) Plaintifrs Third Theory Is Fatal To Request Number 12 Finally, Plaintiffs Fourth Theory is that the tax returns may provide a link in the chain of evidence used to establish a nexus to Epstein's alleged offenses under 18 U.S.C. 2255. As state above, llllllllillThis is exactly why Plaintiff wishes to obtain the requested information - to further prosecute Epstein or assist in the progress of same. Accordingly, for the same reasons expressed herein, Epstein's Fifth Amendment Privilege should be sustained. Wherefore, Epstein respectfully requests that this Conrt issue and order: a. finding that the danger Epstein faces by being forced to testify in this case relative to the above requests is substantial and real, and not merely trifling or imaginary; b. sustaining Epstein's Fifth Amendment Privilege as it relates to the above requests and denying Plaintiffs Motion in that regard; c. reversing and/or revising the Magistrate's Order (DE 462) relative to Request Numbers 10, 12 and 13 and entering an amended order sustaining Epstein's objections to the Magistrate's Order as to those specific requests and not requiring him to produce infonnation relative to same; d. striking as untimely Plaintiffs new arguments in her response in opposition (DE 495) relative to Request Numbers 7, 9 and 10 for failure to file the appropriate Rule 4 Appeal and/or reversing and/or revising the Magistrate's Order (DE Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 16 of 18 Doe v. Epstein 08-CV80119 Page No. 16 462) relative to Request Numbers 7, 9 and 10 and entering an amended order sustaining Epstein's objections to the Magistrate's Order as to those specific requests and not requiring him to produce information relative to same; e. remanding this appeal to the Magistrate-Judge for her reconsideration of these portions of her order; f. alternatively, if this court rules that any of the information requested herein is relevant, it shall only do so after an in camera hearing and only after this court ensures that each and every documents produced is the subject of a heightened- confidentiality order; g. for such other and further relief as this Court deems just and proper. Respectfully submitted, By: Isl Michael J .. Pike MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CMIECF. 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 CMIECF on this 26th day of March, 2010. Respectfully submitted, By: Isl Michale J. Pike ROBERT D. CRITTOl';J, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 303 Banyan Blvd., Suite 400 West Palm Beach, FL 33401 Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010

Page 17 of 18 Doe v. Epstein 08-CV80119 Page No. 17 561/842-2820 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 33160 305-931-2200 Fax: 305-931-0877 [email protected] [email protected] Counsel/or Plaintijft In related Cases Nos. 08-80069, 08-80119, 08- 80232, 08-80380, 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 [email protected] Counsel/or Defendant Jeffrey Epstein Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 [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 561-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08- 80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010