EFTA00181807

Case 9:08-cv-80119-KAM 
Document 305-3 
Entered on FLSD Docket 09/17/2009 
Page 5 of 11 
Case 9:08-cv-80119-KAM 
Document 296 
Entered on FLSD Docket 09/11/2009 
Page 5 of 33 
Page 5 
**• 
The Court: Okay. But again, you're in agreement with everyone else so far 
that's spoken on behalf of a plaintiff that defending the case in the normal course 
of conducting discovery and filing motions would not be a breach? (Et "A," 
p30). 
Mr. Horowitz — counsel for Jane Does 2-7: Subject to your rulings, of course, 
yes. (Ex "A," p.30). 
*** 
The Court: But you're not taking the position that other than possibly doing 
something in litigation which is any other discovery, motion practice, 
investigations that someone would ordinarily do in the course of defending a civil 
case would constitute a violation of the agreement? (Ex. "A," p34). 
Ms. _: 
No, your honor. I mean, civil litigation is civil litigation, and 
being able to take discovery is part of what civil litigation is all about... But. . .
Mr. Epstein is entitled to take the deposition of a Plaintiff and to subpoena 
records, etc. (Ex. "A," p.34) 
12. 
It is clear from the transcript attached as Wait "4" that each of the Plaintiffs' 
attorneys, including Mr. Horowitz for Jane Does 2-8, expected and conceded that 
regular/traditional discovery would take place (i.e., discovery, motion practice, depositions, 
requests for records, and investigations). 
13. 
Importantly, Plaintiffs' counsel advised the undersigned that they coordinate their 
efforts in joint conference calls at least two times per month. At recent depositions of two 
witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned the 
witnesses for approximately six to eight hours, often repeating the same or similar questions that 
had previously been asked. 
14. 
Clearly, the Plaintiffs' counsel wish to control discovery and how the Defendant 
is allowed to obtain information to defend these cases. However, the court has ruled on a 
number of these issues as follows: 
A. 
Plaintiffs' counsels sought to preclude the Defendant from serving third 
patty subpoenas and allowing only Plaintiffs' counsel to obtain 
EFTA00182047

Case 9:08-cv-80119-KAM 
Document 305-3 
Entered on FLSD Docket 09/17/2009 
Page 6 of 11 
Case 9:08-cv-80119-KAM 
Document 296 
Entered on FLSD Docket 09/11/2009 
Page 6 of 33 
Page 
depositions and those materials and "filter them" to defense counsel. 
That motion was denied, and the court tailored a method such that the 
Defendant could obtain the records directly. 
B. 
Plaintiffs' counsels sought to limit earlteddigal
c psychiatric 
examination in C.M.A. v. Jeffrey Epstein 
Case No. 08-
CIV-80811), as to time, subject matter and scope. However, Magistrate 
Johnson entered an order denying the requested restrictions. 
C. 
Other Plaintiffs' attorneys have said that they object to requested 
psychological exam of their client(s), thus motions for such exams will 
now need to be filed; yet all seek millions of dollars in damages for 
alleged psychological and emotional trauma. 
D. 
Many Plaintiffs' object to discovery regarding current and past 
employment (although they are seeking loss of income, both in past and 
funny). 
E. 
All Plaintiffs object to prior sexual history, consensual and forced as 
being irrelevant, although in many of the medical records that are now 
being obtained, as well as the psychiatric exams done by Dr. Kliman, 
there is reference to rape, molestation, abusive relationships (both 
physical and verbal), prior abortions, illegal drugs and alcohol abuse. 
15. 
Clearly, Plaintiffs wish to make allegations; however, they forget that they must 
meet their burden by proving same. Meeting that burden and disproving those allegations is not 
possible if this cowl allows Plaintiffs to stifle and/or control the discovery process. 
18. 
Specifically, with regard to Jane Doe No. 4, which is the deposition set for next 
week, September 16, 2009, the plaintiff has in her past (see affidavit of Richard C.W. Hall, 
M.D., an expert psychiatrist retained by Defendant to conduct exams on various claimants.) aet 
Exhibit "5" 
A 
B. 
C. 
EFTA00182048

Case 9:08-cv-80119-KAM 
Document 305-3 
Entered on FLSD Docket 09/17/2009 
Page 7 of 11 
Case 9:08-cv-80119-KAM 
Document 296 
Entered on FLSD Docket 09/11/2009 
Page 7 of 33 
Par 7
D. 
17. 
There are police reports that reflect that: 
A. 
B. 
C. 
18. 
Moreover, an if
 Jane Doe No. 4 
Within her Amended Complaint and Answers to Interrogatories, 
she indicates that she went to Epstein's house on several occasions. However, at no time did she 
call the police, at no time did she report any traumatic or severe emotional trauma, nor alleged 
coercion, force or improper behavior by Epstein until she got a "lawyer" and is now pursuing 
claims for millions of dollars. Epstein's assistance to his attorneys at these depositions regarding 
the above issues is not only a constitutional due process right afforded to him but essential given 
the fact that this court has ruled that Plaintiffs' depositions can only occur one time, no "second 
bite" absent a court order. 
19. 
Given the breadth of the allegations made against Epstein and the substantial 
damages sought, Epstein has an unequivocal and constitutional right to be present at any 
deposition such that he can assist his counsel with the defense of these cases. kg irg5w. Dr. Hall 
EFTA00182049

Case 9:08-cv-80119-KAM 
Document 305-3 
Entered on FLSD Docket 09/17/2009 
Page 8 of 11 
Case 9:08-cv-80119-KAM 
Document 296 
Entered on FLSD Docket 09/11/2009 
Page 8 of 33 
Page 8 
also prepared affidavits regarding Jane Does 2, 3, 5, 6, and 7, which are attached to DE 
247. 
Memorandum Of Law 
20. 
Plaintiffs' motion is required to be denied as they have failed to meet their burden 
showing the "extraordinary circumstances" necessary to establish good cause to support a 
protective order which would grant the extraordinarily rare relief of preventing a named party 
from attending in person the deposition of another named party. Also requiring denial of 
Plaintiffs' motion is the fact that it seeks to exclude Epstein from all the depositions of all the 
Plaintiffs in actions before this Court. Such relief is unprecedented and attempts to have this 
Court look at the Plaintiffs' collectively as opposed to analyzing each case based on facts versus 
broad speculation whether "extraordinary circumstances" exist on a case by rase basis. In other 
words, the standard is such that the Court would be required to determine whether each Plaintiff 
has met her burden, should the Court consider adopting such extraordinary relief. On its face, 
the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7. 
Discussion of Law Requiring the Denial of the Requested Protective Order 
Rule 26(c)(1XE), Fed.R.Civ P. (2009), governing protective orders, provides in relevant 
part that: 
(1) In General. A party or any person from whom discovery is sought may move for 
a protective order in the court where the action is pending—or as an alternative on 
matters relating to a deposition, in the court for the district where the deposition will 
be taken. The motion must include a certification that the movant has in good faith 
conferred or attempted to confer with other affected parties in an effort to resolve the 
dispute without court action. The court may, for good cause, issue an order to 
protect a party or person from annoyance, embarrassment, oppression, or 
undue burden or expense, including one or more of the following: 
(E) designating the persons who may be present while the discovery is conducted; 
EFTA00182050

Case 9:08-cv-80119-KAM 
Document 305-3 
Entered on FLSD Docket 09/17/2009 
Page 9 of 11 
Case 9:08-cv-80119-KAM 
Document 296 
Entered on FLSD Docket 09/11/2009 
Page 9 of 33 
Page 9
• 
• 
In seeking to prevent the Defendant from being present in the room where the Plaintiffs 
are being deposed, Plaintiffs generally rely on treatise material from Wright & Miller, 8 Federal 
Practice & Procedure Civ.2d, §2041, and cases cited therein. The case of Oaella v. Onassis 487 
F.2d 986, at 997 (2d Cr. 1973), cited by Plaintiffs, makes clear that the exclusion of a party from 
a deposition "should be ordered rarely indeed." Unlike the Gee& case, there is no showing by 
eac of the Plaintiffs that there has been any conduct by Epstein, in rightfully defending the 
actions filed against him, reflecting "an irrepressible intent to continue ... harassment" of any 
Plaintiff or a complete disregard of the judicial process, i.e. prior alleged conduct versus any 
action/conduct displayed in this or other cases that would justify extraordinary relict There is 
absolutely no basis in the record to indicate that Epstein will act other than properly and with the 
proper decorum at the depositions of the Plaintiffs and abide in all respects with the No-Contact 
Order. 
Wherefore, Epstein respectfully requests that this Court enter an order denying Plaintiffs' 
Motion for Protective Order, provide that Epstein is permitted to attend the depositions of the 
Plaintiffs that have asserted claims against him in the related matters, and for such other and 
further relief as this court deems just and proper. 
Robert D. Crjfton, Jr. 
Michael J. lice 
Attorney for Defendant Epstein 
EFTA00182051

Case 9:08-cv-80119-KAM 
Document 305-3 
Case 9:08-cv-80119-KAM 
Document 296 
Page 10 
Entered on FLSD Docket 09/17/2009 
Page 10 of 11 
Entered on FLSD Docket 09/11/2009 
Page 10 of 33 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was hand-delivered to the Clerk 
of the Court as required by the Local Rules of the Southern District of Florida and electronically 
mailed to all counsel of record identified on the following Service List on this 1 I th day of 
Scstegiber, 2009. 
Certificate of Service 
Jane Doe No. 2 v. Jeffrey Epstein 
Case No. 08-CV-80119-MARRAMOHNSON 
Stuart S. Mermelstein, Esq. 
Adam D. Horowitz, Esq. 
Mermelstein & Horowitz, P.A. 
18205 Biscayne Boulevard 
Suite 2218 
Miami. FL 33160 
Fax: 
ttomev.co 
Counsel or Plaint/ s 
In related Cases Nos. 0840069, 0840119, 08-
80232, 08-80380, 0840381, 0840993, 08-
80994 
Richard Horace Willits, Esq. 
Richard H. Willits, P.A. 
2290 10th Avenue North 
Suite 404 
Lake Worth. FL 334.61 
Fax: 
Counsel or Plaintiff In Related Case No. 08-
80811 
Brad Edwards, Esq. 
Rothstein Rosenfeldt Adler 
401 East Las Olas Boulevard 
Suite 1650 
Fort Lauderdale, FL 33301 
Phone: 
Fax: 
80893 
n Related Case No. 08-
Paul G. Cassell, Esq. 
Pro Hac Vice 
332 South 1400 E, Room 101 
Salt Lake Ci , UT 84112 
Im
A itsgr
Fax 
o-cowue or 
inn Jane Doe 
Isidro M. Garcia, Esq. 
Garcia Law Firm, FA-
224 Datura Street, Suite 900 
West Palm Beach, FL 33401 
Jack Scarola, Esq. 
Jack P. Hill, Esq. 
Counsel 
Seamy Denney Scarola Barnhart & Shipley, 80469 
P.A. 
F 
or 
alto i n elated Case No. 08-
EFTA00182052

Case 9:08-cv-80119-KAM 
Document 305-3 
Entered on FLSD Docket 09/17/2009 
Page 11 of 11 
Case 9:08-cv-80119-KAM 
Document 296 
Page 11 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, FL 33409 
, 
Bruce Reinhart, Esq. 
Bruce E Reinhart, P.A. 
250 S. Australian Avenue 
Suite 1400 
West P 
h, FL 33401 
Fax: 
Counsel for
Theodore J. Leopold, Esq. 
Spencer T. Kuvin, Esq. 
Leopold-Kuvin, 
2925 PGA Blvd., Suite 200 
Palm Beach Gardens, FL 33410 
Fax: 
Counsel for Plaintiff in Related Case No. 08
08804 
-
Entered on FLSD Docket 09/11/2009 
Robert C. Josefsberg, Esq. 
Katherine W. Ezell, Esq. 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
30 
Page 11 of 33 
Counsel for P 
sin Related Cases Nos. 
09-80591 and 09-80656 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
Counsel for Defendant Jeffrey Epstein 
Respectfully submi 
By: 
ROBERT 
CRITTON, JR., ESQ. 
Florida 
No. 224162 
MICHAEL J. PIKE, ESQ. 
MOS 
BURMAN, CRITTON, LUTITER & COLEMAN 
303 Banyan Blvd., Suite 400 
FL 33401 
Phone 
Fax 
(Co-Counsel for Defendant Jeffrey Epstein) 
EFTA00182053

• Case 9:08-cv-80119-KAM 
Document 305-4 
Entered on FLSD Docket 09/17/2009 PRttlacif of 2 
Robert D. Critton Jr. 
From: 
Adam Horowitz 
Sent 
Tuesday, September 15, 2009 11:43 AM 
To: 
Michael J. Pike; Robert D. Critton Jr. 
Cc: 
Stuart Mermelstein 
Subject Jane Does v. Epstein 
1 
Please allow this to confirm that Jeffrey Epstein will not attend tomorrow's deposition of Jane Doe No. 4 (in the 
absence of a Court order permitting him to attend). We understand you may wish to have your client listen in by 
telephone or view a videofeed of the deposition, but will not be seen by our client. 
Regards, 
Adam D. Horowitz, Esq. 
WvAv.sexabuseattorney. C0111 
Mermelstein a Horowitz, P.A. 
18206 Biscayne Boulevard 
Suite 2218 
Miami, FL 33160 
Tel: 
Fax: 
From: Michael J. Rice [mato: 
Sent: Tuesday, September 15, 2009 10:54 AM 
To: Stuart Mermelstein; Adam Horowitz 
Cc Robert D. Craton Jr.; Jessica C.adwen 
Subject: EW: Jane Does v. Epstein 
Gentlemen: 
I sent the e-mail below weeks ago. I have not heard back from you. I'm entitled to the 
questionnaires Kliman had your clients fill out and which he utilized to formulate his opinions. I 
need them by tomorrow since they are well over due. If not, I will have no other choice to file a 
motion, which I do not want to do given how we have worked together on these issues in the 
past. Let me know, pike. 
From: Michael J. Pike 
Sent Tuesday, August 18, 2009 11:37 AM 
To: Robert D. CrItton Jr.; Stuart Mermeistein; Ashlie Stoken-Baring; Connie Zaguirre 
Subject Jane Does v. Epstein 
From reviewing the transcripts, it seems Dr. Kliman utilized Questionnaire's with all of your 
clients. I need them. Please advise of your position. I'm sure you will produce since they are 
EXHIBIT 3 
If 
9/15/2009 
EFTA00182054

Case 9:08-cv-80119-KAM 
Document 305-4 
Entered on FLSD Docket 09/17/2009 FlaWg; ga 2 
discoverable. Thanks. 
Michael J. Pike, Esq. 
Burman, Critton, Luttier & Coleman 
515 N. Flagler Dr., Ste. 400 
West Palm Beach, Florida 33401 
Telephone: 
Facsimile 
PRIVILEGED AND CONFIDENTIAL COMMUNICATION 
The information contained in this transmission is attorney/client privileged and/or attorney work product 
If you are not the addressee or authorized by the addressee to receive this message, you shall not review, 
disclose, copy, distribute or otherwise use this message (including any attachments). If you have received 
this e-mail in error, please immediatelynotift the sender by reply e-mail and destroy the message (including 
attachments) and all copies. Thank you. 
9/15/2009 
EFTA00182055

Case 9:08-cv-80119-KAM 
Document 305-5 
Entered on FLSD Docket 09/17/2009 
Page 1 of 3 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOB NO. 2, 
Plaintiff 
I 
JEFFREY B. EPSTEIN, 
Defendant. 
Related Cases: 
08-80232, 08-80380, 08-80381, 08-80994, 
08-80993, 08-80811, 08-80893, 09-80469, 
09-80581, 09-80656, 09-80802, 09-81092. 
AFFIDAVIT OF
STATE OF FLORIDA 
) SS 
COUNTY OF PALM BEACH 
) 
BEFORE ME, the undersigned authority, personally appeared Jeffrey B. Epstein 
having personal knowledge and being duly sworn, deposes and says: 
1. 
My office is located at 250 Australian Avenue South, 14m Floor, We Palm 
Beach, Florida. Its location has been well publicized in the news. 
2. 
I met with my attorneys, Robert D. Critton, Jr. and Mark T. Luther, at 12:30 p.m. 
in preparation for the deposition of Jane Doe No. 4 which was to take place beginning at 1:00 
p.m. on September 16, 2009. 
3. 
I was aware of the motion for protective order which bad been served in this case 
by counsel for lane Doe No. 4 and the Emergency Motion To Stnle Plaintiff's Motion For 
EXHIBIT 
EFTA00182056

Case 9:08-cv-80119-KAM 
Document 305-5 
Entered on FLSD Docket 09/17/2009 
Page 2 of 3 
Jane Doe No. 4. Epstein 
Page 2 
Protective Order And Emergency Motion To Allow The Attendance Of reffmy Epstein At The 
Deposition Of Plaintiffs And Response In Opposition To Plaintiff?, Jane Doe Nos. 2-8, Motion 
For Protective Order As To Jeffrey Epstein's Attendance At The Deposition Of Plaintiffs, With 
•
rporated 
oiandum ataciv-bia ha bierifiled ciii thy baleen& that I Obtanttekl • 
the deposition and assist my attorneys in my defense. 
4. 
I also understood that as of 1:00 p.m. on September 16, after I had finished 
speaking with my attorneys that the court had not ruled regarding the above-referenced motions. 
5. 
I was instructed by my attorneys that I could not attend the deposition and 
therefore a video feed was set up such that I could view the deposition from my home. 
6. 
I also understood that my attorneys did not want me in the building after the 
deposition began. 
7. 
At 1:04 p.m. after we assumed that everyone would be in the deposition room, my 
lawyers went down on one elevator and I went' down on another elevator with my driver, Igor 
Zinoviev, both exiting at approximately the same time. 
8. 
I asked Igor where he had parked, and he said "out front". 
We ached the 
elevator, I walked toward the front door. Near the front door, I saw a taller woman and a 
shorter woman who I thought might be lane Doe No. 4 and immediately turned to my left and 
went out a separate exit to the garage. 
9. 
At no time did I speak with or attempt to interact with either women. 
FURTHER THE AFFIANT SAYETH NAUGHT. 
EFTA00182057

Case 9:08-cv-80119-KAM 
Document 305-5 
Entered on FLSD Docket 09/17/2009 
Page 3 of 3 
Jane Doe No. 4 v. Epstein 
Page 3 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
Iiiirebireeriky that on t7 a day, -before Meiji officer duly Mitberlieil to edminieDer 
oaths and take acknowledgments, personally appeared Jeffrey E. Epstein known to me to be the 
person described in and who executed the foregoing Affidavit, who acknowledged before me 
that be/she executed the same, that I relied upon the following form of identification of the above 
named person:  3 • 14.41 r es4-, 
, and that an oath was/was not taken. 
WITNESS my hand and official seal in the County and State last aforesaid this 
day of Sy+. 17 
, 2009. 
NOTARY PUBLIC/STATE OF 14-1/064 1 -1"
) 
COMMISSION NO.: 
MY COMMISSION
Msic
(SEAL) 
•%%=tk.
 . 1.1.41.4", 
.7... z,,*°÷1 0TAtty. %IA 
:: 0: 
• .1.*:-; 
: My Comm. Itaos 
May* 20113 
S. 03519957 
6% Pow° 
cAy.z". ... ..
.. 
.... 
• 
,,,,,,,,,,,, 
EFTA00182058

Case 9:08-cv-80119-KAM 
Document 305-6 
Entered on FLSD Docket 09/17/2009 
Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOB NO. 2, 
Plaintiff, - 
JEFFREY 'EPSTEIN, 
Defendant. 
Related Cases: 
08-80232, 08-80380, 08-80381, 08-80994, 
08.80993, 08-80811, 08-80893, 09-80469, 
09-80581, 09-80656, 09-80802, 09-81092. 
AFFIDAYTT OF IGOR ZINOVIEV 
STATE OF FLORIDA 
) SS 
COUNTY OF PALM BEACH 
) 
BEFORE MR, the undersigned authority, personally appeared Igor Zinoviev 
having personal knowledge and being duly sworn, deposes and says: 
1. 
I work for Jeffrey Epstein. I as well drive him from place to place. 
2. 
At approximately 1:04 p.m., Mr. Epstein and I went down in the elevator from the 
14th floor to the ground leveL I was to drive Mr. Epstein to his home. His lawyers went down at 
approximately the same time in a separate elevator. 
3. 
I parked the car at the flout entrance. As I walked toward the front door and 
noticed that Mr. Epstein quickly turned to the left so as to exit through the door to the garage of 
the building rather than the front entrance. 
EXHIBIT 
EFTA00182059

Case 9:08-cv-80119-KAM 
Document 305-6 
Entered on FLSD Docket 09/17/2009 
Page 2 of 2 
Jane Doe No.4 v. Epstein 
Page 2 
4: 
At no time did Mr. Epstein speak or gesture to anyone, including the individuals 
whom I saw near the front door. 
5. 
At no time did I speak with the individuals at the main entrance. 
FURTHER THE ICFFIANT SAYETH NAUGHT. - 
e e•- % 
___Lra
ie-crev 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
I hereby Certify that on this day, before me, an officer duly authorized to administer 
oaths and take acknowledgments, personally appeared Igor Zinoviev known to me to be the 
person descried in and who executed the foregoing Affidavit, who acknowledged before me 
that he/she executed the same, the; 'relied upon the following form of identification of the above 
named person:  a 411  
, and that an oath was/was not taken. 
WITNESS my hand and official seal in the County and State last aforesaid this 
day of 
cid, n, 
 2009. 
tttt 
,,,,, 
At-k}r.t A R y , </1St% 
ese 
weiL
i1O
atteil
Tiz 
;467oossw-- i.,,(110TARY PUBLIC/STATE OF 
(SEAL)
= 
ptietNc" 
• 
COMMISSION NO.: 
S;91
:44re ,,, t\ic` s 
MY COMMISSION EXPIRES: 
tttttttttttttt 
EFTA00182060

Case 9:08-cv-80119-KAM 
Document 305-7 
Entered on FLSD Docket 09/17/2009 
Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
JP...H.R.EY EPSTEIN, 
Defendant. 
Related Cases: 
08-80232, 08-80380, 08-80381, 08-80994, 
08-80993, 08-80811, 08-80893, 09-80469, 
09-80581, 09-80656, 09-80802, 09-81092. 
AFFIDAVIT OF ROBERT D. CRITTON, JR. 
STATE OF FLORIDA 
) SS 
COUNTY OF PALM BEACH 
) 
BEFORE ME, the undersigned authority, personally appeared Robert D. Critton, Jr., 
having personal knowledge and being duly sworn, deposes and says: 
1. 
I am counsel for Jeffrey Epstein in the above-styled matter and other civil 
lawsuits. 
2. 
The information contained in motion, paragraphs 1 through 9, 11, 13, 14 and 16 
is true and accurate based on my personal knowledge. 
3. 
The costs and fees set forth in the motion are true, correct and reasonable. 
FURTHER THE AFFIANT SAYETH NAUGHT. 
Robert . Critton, Jr. 
.XHIBIT 6 
EFTA00182061

Case 9:08-cv-80119-KAM 
Document 305-7 
Entered on FLSD Docket 09/17/2009 
Page 2 of 2 
Jane Doe No. 4 v. Epstein 
Pape 2 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
I hereby Certify that on this day, before me, an officer duly authorized to administer 
oaths and take acknowledgments, personally appeared Robert D. Critton, Jr.. known to me to be 
the person described in and who executed the foregoing Affidavit, who acknowledged before me 
that he/she execu ,the same, that I relied upon the following formo 
'on of the above 
named person:  nisfit 
,t4eat.44 
, and that an oath w 
WI'I'jESS my hand and official seal in the County and State last aforesaid this 
day of/
 Vanhe
7 , 2009. 
NAME: 
C./ 
NOT 
LIC/STATE OF FLORIDA 
COMMISSION NO.: dl) 8535, 9 
MY COMMISSION EXPIRES: tiyi ? 
EFTA00182062

Case 9:08-cv-80119-KAM 
Document 305-8 
Entered on FLSD Docket 09/17/2009 
Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
Related Cases: 
08-80232, 08-80380, 08-80381, 08-80994, 
08-80993, 08-80811, 08-80893, 09-80469, 
09-80581, 09-80656, 09-80802, 09-81092. 
AFFIDAVIT OF MARK T. LUTHER 
STATE OF FLORIDA 
) SS 
COUNTY OF PALM BEACH 
) 
BEFORE ME, the undersigned authority, personally appeared Mark T. Luther., having 
personal knowledge and being duly sworn, deposes and says: 
1. 
I am counsel for Jeffrey Epstein in the above-styled matter and other civil 
lawsuits. 
2. 
The information contained in motion, paragraphs 1 through 10, 11, 13, 14 and 16 
is true and accurate based on my personal knowledge. 
FURTHER THE AFFIANT SAYETH NAUGHT. 
Pat 
Mark T. Luther 
EXHIBIT 7 
EFTA00182063

Case 9:08-cv-80119-KAM 
Document 305-8 
Entered on FLSD Docket 09/17/2009 . Page 2 of 2 
Jane Doe No. 4 v. Epstein 
Pape 2 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
I hereby Certify that on this day, before me, an officer duly authorized to administer 
oaths and take acknowledgments, personally appeared Mark T. Luttier, known to me to be the 
person described in and who executed the foregoing Affidavit, who acknowledged before me 
that he/she executed the same, that I relied upon the following form of identification of the above 
named person:  
71,74 /7, ,,e-7e44->7 , and that an oath was/was not taken. 
W
S.)S mx_ hand and official seal in the County and State last aforesaid this /r
e/
day of  r5,0C 
 2009. 
ita41-e-",
PRINT NAMEr7 55/C1 ctioeste.R___ 
NOTARY PUBLIC/STATE OF FLORIDA 
COMMISSION NO.: Ob 853 $;9 
MY COMMISSION EXPIRES: ,aVelpy 
EFTA00182064

Case 9:08-cv-80119-KAM 
Document 305.9 
Entered on FLSD Docket 09/17/2009 
Page 1 of 3 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-CV-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 
 
/ 
DEPOSITION OF JANE DOE #4 
Wednesday, September 16, 2009 
1:03 - 1:08 p.m. 
250 Australian Avenue South 
Suite 115 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting 
EXHIBIT Ii? 
PROSE COURT REPORTING AGENCY, INC. 
Eloctronleally signed by Wallis ItoPichis iftle 
d'2a4384445042•646t1.68B7d7MIW6 
EFTA00182065

Case 9:08-cv-80119-KAM 
Document 305-9 
Entered on FLSD Docket 09/17/2009 
Page 2 of 3 
Page 2 
1. 
2 
3 
APPEARANCES: 
On &Slott PbastifIl 
ADAM D. MOROWITZ, ESQUIRE 
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MERME1STEIN a HOROWITZ. PA 
18205 Bbarice Baukased 
Suite 2218 
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Paea
lvgani.
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On behalf of the DeRadsat 
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ROBERT D. CRITTON, JR ESQUIRE 
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MARK T. LUTIDIR. ESQUIRE 
BURMAN. CANTON, LUITIERR COLEMAN. L1P 
303 Bram Boulevard 
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Sate 400 
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West 
33401 
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Phone 
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0a Wulf 
JAOC ALAN GOLDBERGER. ESQUIRE 
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ATTERBURY, GOLDBERGER* WEER PA 
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250 AS:am Avec= South 
Sulse 1400 
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15 
Was 
33401.5012 
33401-5012 
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Ph011t 
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Out behatfallA4 and SW: 
W1111A1411. BERGER. ESQUIRE 
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ROTHSTEIN. FtOSENFELDT. ADLER 
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401 Bs Lau OW Boakard 
Are 1650 
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Pod latillara 
3330) 
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21. 
Tom 
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Oa Oshatfolf04A.: 
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JACK P. H11/, ESQUIRE 
SEARCY. DENNEY. SCAROLA. 
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BAR/MART& SHIPLEY. P.A. 
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2139 Palm Beach Lakes 8Snvd 
West Palm Beach Fkilda 33409 
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Page 3 
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APPPARNCES CONTINUED_ 
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On behalf of BE: 
ADAM J. LANGINO, ESQUIRE 
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LEOPOLD KUVIN 
2925 PGA Boulevard 
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Suite 200 
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6 
Phhn 
Florida 33410 
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Phone: 
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3.0 
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Page 4 
PROCEEDINGS 
MR HOROWITZ: Adam Horowitz, counsel for 
Plaintiff, Jane Doe 4. 
MR. CRITTON: Cindy, what tint is it? 
THE COURT REPORTER: It is 1.03. 
MR BERGER: William J. Berger for LM and 
EW. 
MR. HILL Jack Hill for CMA. 
MR LANGINO: Adam Langino from 
Leopold KUVill on behalf of BB. 
MR LUTHER: Mark Luttier on behalf of 
Busman, Critton, Luttier & Coleman Sr the 
Defendant. 
MR_ CRITTON: Robert Ctinon on behalf of 
Defendant, Jeffrey Epstein. 
MR. HOROWITZ: This is Adam Horowitz. 
We're canceling today's deposition. Before 
appearing here today, we bad a stipulation with 
Defense counsel that Mr. Jeffrey Epstein, the 
Defendant, would not be hat. He would not 
cross paths with our client 
And immediately as we were approaching the 
deposition mom, he made face-to-face contact 
with eta client. He was just feet away from 
Page 5 
her and intimidated her, and for that mason 
we're not going forward. 
MR. CRTITON: I didn't see any contact 
because I, obviously, was not out there. We 
started at about — when you came in it was 
approximately 1:03. Mr. Epstein has an office 
here at the Florida Science Foundation. Had 
you been here at 1:00, your paths never would 
have crossed because Mr. Epstein was leaving 
the building I instructed him to leave the 
building so that he would not be here. 
He was going to appear by way of Skype so 
that he could be on a video camera so that he 
could see this. 
(Mr. Goldberger entered the room) 
MR CRTITON: Had you been here on time, 
and not faulting, lam just saying had you been 
here on time at 1:00, as everyone else seemed 
to be here at least get here before you did, 
Adam, you and your client your paths never 
would have crossed. 
I directed Mr. Epstein to leave the 
building so he would not be here so that there 
would be no way that your paths could have 
crossed. It was neither my intent nor was it 
2 (Pages 2 to 5) 
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