EFTA02729648

Case 9:08-cv-80119-KAM Document 305-4 Entered on FLSD Docket 09/17/2009 Pirafgbef ar 2
Robert D. Critton Jr.
From: Adam Morowitz iahorowitzesexabuseetbxney.corni
Sent: Tuesday, September 15, 2009 11:43 AM
To: Michael J. Pike; Robert D. Critton Jr.
Cc: Stuart Mermeisteln
Subject: Jane Does v. Epstein
Please allow this to conform 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 dent.
Regards,
Adam D. Horowitz, Esq.
www.sexabuseattorney.com
atermeterein a Horowitz, P.A.
18205 Biscayne Boulevard
Suite 2218
Miami, FL 33160
ctharowitztheztabuseattornev.cont
Tel: (305) 931-2200
Fox: (305) 931-0877
From: Michael J. Plke [mallbs:MPIkeetciclaw.ccin]
Sent Tuesday, September 15, 2009 10:54 AM
To: Stuart Mermcistain; Adam Horowitz
Cc Robert D. Crtton 3r.; Jessica Cadwell
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: Midmel J. Pike
Sent Tuesday, August 18, 2009 11:37 AM
To: Robert D. Critton Jr.; Stuart Memcbtein; Ashlie Stoker-Badng; Connie Zagulrre
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
3
EXHIBIT
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Case 9:08-cv-80119-KAM Document 305.4 Entered on FLSD Docket 09/17/2009 liaita 99f 2
discoverable. Thanks.
Michael J. Pike, Esq.
Burman, Critton, Luther & Coleman
515 N. Flagler Dr., Ste. 400
West Palm Beach, Florida 33401
Telephone: (561) 842-2820
Facsimile (581) 844-6929
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 ox authorized by the addressee to receive this message, you shall not review,
disclose, copy, distdbute or otherwise use this message (lnchiding any attachments). If you have received
this e-mail in error, please immediately notify the sender by reply e-mail and destroy the message (including
attachments) and all copies. Thank you.
9/15/2009
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Case 9:08-cv-80119-KAM Document 305.5 Entered on FLSD Docket 09/17/2009 Page 2 of 3
Jane Doe No.4 v. Epstein
Pane 2
nth
Protective Order AM Emergency Motion To Allow Attendance OfJeffrey Epstein At The
Deposition Of Plaintiffs And Response In Opposition To Plaintiff:', am Doe Nos. 2-8, Motion
For Protective Order As To Jeffrey Epstein's Attendance At The Deposition Of Plaintiffs, With
ffifemoiindwn Ottat,"ividal tia litielifiled did my saiiirivehthat T othittratretid •
the deposition and assist my attorneys in my dense.
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.
S. 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 pm. after we assumed that everyone would be in the deposition mom, my
lawyers went down on one elevator end 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 exited the
elevator, I walked toward the front dodr. Near the front door, I saw a taller woman and a
shorter woman who I thought might be Jane Doe No. 4 and immediately turned to my left and
went out a separate exit to the garage.
9. M no time did I speak with or attempt to interact with either women.
FURTHER THE AFFIANT SAYETH NAUGHT.
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Case 9:08-cv-80119-KAM Document 305-5 Entered on FLSD Docket 09/17/2009 Page 3 of 3
Jane Doe No. a v. Epstein
Page
STATE OF FLORIDA
COUNTY OF PALM BEACFI
hereby Se that. On. day, hefoie me, an ACC* &if itithoiiiid to
oaths and take ac/cnowledgmener, personally appeared Jeffrey E. Bpetein known to me to be the
person described in and who executed the foregoing Affidavit, who wrimowledged before me
that he/she executed the same, that I relied upon the following form of identification of the above
named pawn: .le res4-0 and that anoath watAvas not taken.
WITNESS my band and official seal in the County and State last aforesaid this
day of S . I 2009.
Mai
31v n Lf (sEms)
NOTARY PUBLIC/STATE OF FLORIDA i .•
COMMLSSION NO.: •
MY COMMISSIONnEtES:
Wits
tr °744 .t) :,
My Owen DSO
Maria 2010 •
W. COMeeli
Sfy..4°usoo..4bel
4?,?;: teCep
......
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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-CV401194IARRA-JOHNSON
JANE DOB NO. 2,
Pla -
v.
JEFFREY EPSTEIN,
Defendant.
Related Cases:
08-80232, 08-80380, 08-80381, 08-80994,
08-80993, 08-80811, 08-80893, 0940969,
09-80581, 09.80656,09-80802, 09-81092.
AFFIDAVIT OF IGOR ZINOVIIIV
STATE OF FLORIDA ) SS
COUNTY OF PALM BEACH )
BEFORE ME, the undersigned authority, peraonally appeared Igor Zinoviev
having personal knowledge and being duly sworn, deposes end 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
14° 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 padood the car at the Boat entrance. As I walked toward the front door and
noticed that Mr. Epstein quickly tamed to the left so as to exit through the door to the garage of
the building rather than the front entrmice.
EXHIBIT
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Jane Doe No.4 v. Epstein
Pape 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 die individuals at the main entrance.
FURTHER-TEM AFFIANTSAYETEINADOHT.
o sty
U aev
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 ackranvIedgments, personally appeared Igor Zinoviev known to me to be the
person deserWed in and who executed the foregoing Affidavit, wbo acknowledged before me
that he/she executed the same, thakI relied upon the following form of identification of the above
,
named person: a dir t and that an oath was!was not taken.
WITNESS my hand and official seat in the Courty end State last aforesaid this
day of Srek fl 2009.
t i ,-k /s - " ) ° r T • AR? , ,,,,,
typISI4
1AV 00 200 (SEAL)
trrrioosael° 1,43TARY PUBLIC/STATE OF F DA
nuat.‘90:41.0.:? COMMISSION NO.:
........ (rs
, ,,,,,,,,,,,
MY COMMISSION EXPIRES:
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CM 9:08-cv-80119-KAM Document 305-7 Entered on FLSD Docket 09/17/2009 Page I 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 ROBERT D. CROTON. 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:
I. 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, t3, 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.
6
.XHIBIT
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Case 9O8-cv-50119-KAM Document 305-7 Entered on FLSD Docket 09/17/2009 Page 2 of 2
Jane Doe No. 4 v. Epstein
PM* 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 form o 'on of the above
named person: aitirt, A/Own and that an oath
my hand and official seal in the County and State last aforesaid this
day of Min -41 0SS/tn.ht, 2009.
NOT • LIC/STATE OF FLORIDA
6.0856,P
COMMISSION NO.:
MY COMMISSION EXPIRES: iw/ p 3
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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, 0840994,
08-80993, 08-80811, 08-80893, 09.80469,
09-80581, 09-80656, 09.80802, 09-81092.
AFFIDAVIT OF MARK T. UMW%
STATE OF FLORIDA ) SS
COUNTY OF PALM BEACH )
BEFORE ME, the undersigned authority, personally appeared Mark T. Luttiet, having
personal knowledge and being duly sworn, deposes and says:
1. 1 am counsel for Jeffrey Epstein in the above-styled matter and other civil
lawsuits.
2. The information contained in motion. paragraphs I through 10, 11, 13, 14 and 16
is true and accurate based on my personal knowledge.
FURTHER THE AFFIANT SAYETH NAUGHT.
YlAtilt v1 evis
Mark T. Luther
EXHIBIT 7
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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
1 hereby Certify that on this day, before me, an officer duly authorized to administer
oaths and take acknowledgments, personally appeared Mark T. Lanier, known to me to be the
person described in and who executed the foregoing Affidavit, who acknowledged before me
that he/she exec,ed the sams that I relied upon the following form of identification of the above
named person: 6 0:0/4 *AI deezo.4, 7 , and that an oath was/was not taken.
a hand and official seal in the County and State last aforesaid this
day of • 2009.
12.4,41 4-"e e
PRINT NAM/3'7 55/of C4affia-c-
NOTARY PUBLIC/STATE OF FLORIDA
COMMISSION NO.: Ob 653 5 GP"
MY COMMISSION EXPIRES: atifrip ..?.
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Case 9:08-cv-80119-MM 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,
-v9-
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 Ig
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Elleallealty signed by eynthle Metro 0014414764934) 420419434013-42•6413414447420090
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Case 9.08-cv-80119-KAM Document 305-9 Entered on FLSD Docket 09/17/2009 Page 2 of 3
Page 2 Page 4 I
1 2 C A o P e P W EA a R i A te N / C e E l S P : U RSE 1 PROCEEDINGS
I ADAM D. 513ROWTIZ 1391111312 2 - - -
• A :C C O R S IN E Z i I m ST p E a I l N lo o A t a H w O e R d O WITZ. PA 3 MR. HOROWITZ: Adam Horowitz, counsel for
SAS 7211 4 Plaintiff, Jane Doe 1.
S Ides. SAL 33160 5 MR. CRITION: Cindy, what time is it?
Phew %ISSN /20)
g 6 THE COURT REPORTER: 8 is 1:03.
7 cebsbalofte Daman
s =ear D. CAMP& .71.. MAIM 7 MR. BERGER: William .1.Bager for LM and
MAPS T. Lunt° . MOM 8 SW.
s BEIRMAN. =TICK WITIER k COLEMAN. LIP
)0) Raw Douirsd 9 MR. HILL: Jack Hill for CMA.
14 9 W .6 e 4 s 0 P 5 A 0 S Bask *St 3301 10 MR. LA/4GINO: Adam [engin° from
11 Plea 561.1423820 11 Leopold Kuvin on behalf of BB.
1 12 3 On M 041 a 55 t 1 5 A e L f N AN a r G y O ? L p C i O a 20127.55QUEIZ 12 MR. LUPT1ER: Mask Limier on behalf of
ATIEEDUIY. 001,131117.4GER & MS. PA 13 Elam's; Onto°, Lustier & Coleman for the
14 1 S 1 u 0 li e A N i C st O a iso Awes Seco 14 Defendant.
IS WeRP6mEocialadda 1340140n 15 MR. CARTON: Robert Criuce as behalf of
Ms 361.450.1300
14 16 Defendant, Jaffna' Efancia•
1 It 7 Os W be i i l a l l i f a e m gl J A . B la E il R E G V S : * ESQUIRE 17 MR. HOROWITZ: This is Adam iiceowiM.
235.131STE04110612070.156. ADLER 18 We're canceling todays deposition. Before
It 9 m . a M i s 1 r 6 5 L 0 a s ode anew/4 1 9 appearing here today, we had a stipulation with
22 Pet Latabka Facia 33301 20 Defense counsel that Mr. Jeffrey Epstein, the
21 Mot 9543223456 21 Defendant, would not be here. He would not
22 Os Wolf ofOIA: 22 MO plan with ow client.
21 JACR P. IOU. ESQUIRE
SEARCY. DENNEY. SCARO1A 23 And immediately n we were approaching the
24 BARNHART* MAZY. PA 24 deposition room, he made facototace 4500151Ct
2139 Pan lkoch Lain Boulew4
IS West Pike Sack &tido 35405 25 with oar Clint He was just feet away from
Page 3 Page 5
1 APPEARNCES CONTINUED... 1 her and intimidated ha, and for that reason
2 2 were not going forward.
3 On behalf of BB: 3 MR. CRITTON: I didn't see any contact
• ADAMS. CAMINO, ESQUIRE
4 because 1, obviously, was not out there. We
LEOPOLD KUV1N
5 started at about — when you came in it was
S 2925 PGA Boulevard
Suite 200 6 approximately 1:03. Mr. Epstein has an office
6 Palm Beach Gardens, Raids 33410 7 here at the Florida Science Foundation. Had
Phone: 561.515.1400 8 you been here at 1:00, your paths neva would
7 9 have crossed because Mr. Epstein was leaving
8 10 the building. I instructed him to leave the
9 11 building so that he would not be hem
to
12 Hewn going to appear by way of Skype so
11
13 that he could be on a video camera so that he
12
13 14 could see this.
14 15 (Mr. Goldberger altered the room.)
15 16 MR. CRITTON: Had you been here on time,
16 17 and not faulting, lam just saying had you boat
17 18 here co time at 1:00, as vneryoue else seemed
18
19 to be hue at least get here before you did,
19
20 Adam, you and your client, your paths never
20
21 would have crossed.
21
22 22 I &wed Mr. Epstein to leave the
23 23 building so he would not be here so that there
24 24 would be no way that your paths could have
25 25 crossed. It was neither my intent nor was it
2 (Pages 2 to 5)
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
132007.11,7011Y 0410041 ay 0012562 h,s (601-0514/78-2834) th43440.450-42•646414487.12019•5
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Page 6 Page 81
1 my client's intent specifically, because I also 1 CERTIFICATE
2 advised him that he was not to cross paths, not 2
3 to have any contact with your client, and 3 STATE OF FLORIDA
4 certainly by ow agreement not to be here today 4 COUNTY OF PALM BEACH
5 for the deposition. 5
6 MR. HOROWITZ: And at approximately 1:00 6
7 is when my client crossed paths with I, Cynthia Hopkins, Registered Professional
8 JefmfitmyEyp stein. And not only did be cross 6 Reporta and Florida Professional Repeater, State of
9 paths but he proceeded to stare her down just 9 Florida at large, aunty that I was authorized to
10 feet away from her. For that reason she became 10 and did stenographically report the foregoing
11 an emotional wreck and cannot proceed with the 11 proceedings and that the transcript is a true and
12 deposition. She's simply not in an emotional 12 complete record of my stenographic notes.
13 Dated this 16th day of September, 2009.
13 state to do so.
14
14 And in addition Mr. Epstein violated the
15
15 agreement between counsel that he would not
16
16 cross paths or come into contact with ow 4414) As 41)
17 chat And it will be also for the criminal 17
18 caul judge to decide whether he has violated a 18
19 no-contact order. I have nothing else to say. 19
20 MR. CRITTON: Again I instructed 20
21 Mr. Epstein to leave the building so absolutely 21
22 no contact could mew between he and 22
23 Mr. Horowitz and his client nor anyone else. 23
24 Until the court, until either Judge Marra or 24
25 Judge Johnson nded on the issue as to whether 25
Page 7
1 or not he could appear at the depositions of
2 not only Jane Doe 4 but any other individuals,
3 so you do what you need to do.
4 MR. HOROWITZ: Off the record.
5 (The Deposition was concluded.)
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
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23
24
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3 (Pages 6 to 8)
(561) 832 - 7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronic:any signed by creels hooker (601461476-2934) 424.436•34513-42•64441-6687(O0ffileS
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