on excerpt of Jane Doe No. 4’s mother. 7. Defendant now wants to take the deposition of Rocky Orezzoli, Jane Doe No. 4’s college soccer coach, and Bill Brown, Doe No. 4’s soccer coach in middle and high school. The past conduct of Epstein’s counsel suggests that they intend to disclose to these witnesses

preventing Epstein from deposing third parties, including two individuals that were Jane Doe 4's soccer coaches for years (i.e., Rocky Orezzoli and Bill Brown). Limiting such discovery would undoubtedly result in reversible error. Plaintiff claims Epstein is harassing her by way of seeking those depositi

Epstein’s counsel on April 30, 2010, while the Motion was pending. However, the Motion remains ripe with regard to the subpoena for deposition of Bill Brown, another former soccer coach of Jane Doe No. 4. 2. Epstein repeatedly postures that Plaintiff is “yet again” seeking to stonewall his discovery e