Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80119-MARRA/JOHNSON CASE NO 08-CV-80232-MARRA/JOHNSON I CASE NO 08-CV-80380-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I CASE NO 08-CV-80381-MARRA/JOHNSON JANE DOE NO Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Doe Epstein Page2 Plaintiff JEFFREY EPSTEIN Defendant I JANE DOE NO Plaintiff JEFFREY EPSTEIN Defendant I JANE DOE NO Plaintiff JEFFREY EPSTEIN Defendant I C.M.A Plaintiff JEFFREY EPSTEIN Defendant I JANE DOE CASE NO 08-80994-CIV-MARRA/JOHNSON CASE NO 08-80993-CIV-MARRA/JOHNSON CASE NO 08-80811-CIV-MARRA/JOHNSON CASE NO 08-80893-CIV-MARRA/JOHNSON Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Doe Epstein Page3 Plaintiff JEFFREY EPSTEIN et al Defendants I DOEU Plaintiff JEFFREY EPSTEIN et al Defendants I JANE DOE NO Plaintiff JEFFREY EPSTEIN Defendant I JANE DOE NO Plaintiff JEFFREY EPSTEIN Defendant I CASE NO 09-80469-CIV-MARRA-JOHNSON CASE NO 09-80591-CIV-MARRA-JOHNSON CASE NO 09-80656-CIV-MARRA/JOHNSON DEFENDANT JEFFREY EPSTEINS RESPONSE TO JANE DOE NO AND JANE DOE NO MOTION FOR A NO CONTACT ORDER Case Document Entered on FLSD Docket Page of Case Document Doe Epstein Page4 Entered on FLSD Docket Page of Defendant JEFFREY EPSTEIN MR EPSTEIN by and through his undersigned attorneys responds to the Plaintiffs Jane Doe No and Jane Doe No Plaintiffs Motion for a No Contact Order DE and states I Plaintiffs Motion was completely unnecessary and a waste of attorney time and judicial resources Plaintiffs motion was filed to cast a false light on Mr Epstein and his attorneys and to draw attention away from the fact that many of the alleged victims on the referenced list were or are admitted prostitutes dancers at strip clubs Platinum Gold Cheetah Diamond Dolls Ts Lounge Flashdance etc or have criminal records or warrants for their arrests to reference only a few issues about them Plaintiffs seek an advisory opinion on an issue which does not exist Neither Mr Epstein nor his attorneys have initiated any contact direct or indirect with any alleged victims nor does Plaintiffs counsel or any alleged person by way of affidavit alleged any type of contact direct or indirect The undersigneds May Exhibit hereto letter could not have been clearer as to the position of Mr Epstein and his attorneys i.e To my knowledge neither Mr Epstein nor any attorney or agent of those attorneys who represent Mr Epstein have contacted or attempted to contact your clients Given that it is not Mr Epsteins intention to have any direct contact with your clients it is unnecessary to respond point by point to any statements attributed to my co-counsel To the extent it was not clear in the undersigneds letter neither Mr Epstein nor his attorneys nor their agents intend to have any direct or indirect contact with Plaintiffs counsels clients What else is there to say Is Plaintiffs counsel suggesting that Mr Epstein cannot even be at the depositions of his clients as parties or witnesses That certainly will be direct eye contact at a Case Document Entered on FLSD Docket Page of Case Document Doe Epstein Page Entered on FLSD Docket Page of minimum If that is Plaintiffs position then Jane Doe and and any other matters where Plaintiffs finns clients are involved should be stayed until expiration of the Non-Prosecution Agreement otherwise Mr Epstein will be denied his due process right of any civil party to be present at opposing partys deposition Rather than to mislead the court by providing a substantially redacted copy of the undersigneds May letter a full copy of the letter redacting only the clients full name is attached as Exhibit The letter is important in that the Defendant and his attorneys recognize that no contact included not serving his client with a deposition subpoena through a process server i.e potentially an agent by serving her attorney As this court will note from paragraph of Exhibit a very cautious approach was taken by Defendant and his attorneys in stating However based on the position that you Bob have taken I am providing/serving you with the subpoena for L.S.P deposition on June Plaintiffs counsel further tries to obfuscate Defendants position by redacting the last paragraph of the May letter which states Finally as I also indicated in our telephone conversation your client contacted Jack Goldbergers one of Mr Epsteins attorneys office last week suggesting that Jack was holding up the settlement He did not speak with her I dont know where Ms got that idea Plaintiffs counsel should be more concerned about controlling their own clients Rather than the Plaintiffs filing this needless unwarranted and excessive motion where they take another shot at Mr Epstein so they can remind the court of their alleged damages maybe they should focus more on the background of their own clients including the individual referenced in the May letter Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Doe Epstein Page6 Finally Mr Epstein pled guilty to one count of felony solicitation which was not related to a minor under F.S and one count of procuring a minor for prostitution under Plaintiffs reference to both counts being related to minors is again misleading and incorrect At the time of the state court plea on June neither Defendant nor his counsel nor the state attorneys office had seen the secret list of alleged victims i.e Mr Epstein was forced to agree to a list of individuals that the USAO refused to provide pre-plea The list was not provided to Mr Epsteins attorney until after the plea and Mr Epstein was in jail With the parties to the plea completely unaware who would be on the list how then could the state plea be construed as a limitless no contact order Mr Epstein is doing more than the law requires WHEREFORE Defendant Mr Epstein requests this court deny the motion as premature and unnecessary based on the current state of the facts 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 th day of May Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Doe Epstein Page By ROBERT RITTON JR ESQ Florida Bar rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Flagler Drive Suite West Palm Beach FL Phone Fax Counsel for Defendant Jeffrey Epstein Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Doe Epstein Page Certificate of Service Jane Doe No Jeffrey Epstein Case No 08-CV-80119-MARRA/JOHNSON Stuart Mermelstein Esq Adam Horowitz Esq Mermelstein Horowitz P.A Biscayne Boulevard Suite Miami FL ssm sexabuseattomey.com ahorowitz sexabuseattomey.com Counsel for Plaintiffs in Related Cases Nos Richard Horace Willits Esq Richard Willits P.A th Avenue North Suite Lake Worth FL Fax Counsel for Plaintiff in Related Case No reelrhw hotmail.com Jack Scarola Esq Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL Fax jsx searcylaw.com jph searcylaw.com Counsel for Plaintiff CM.A Brad Edwards Esq Rothstein Rosenfeldt Adler East Las Olas Boulevard Suite Fort Lauderdale FL Fax bedwards rra-law.com Counsel for Plaintiff in Related Case No Paul Cassell Esq ProHac Vice South Room Salt Lake City UT Fax cassellp law.utah.edu Co-counsel for Plaintiff Jane Doe Isidro Garcia Esq Garcia Law Firm P.A Datura Street Suite West Palm Beach FL isidrogarcia bellsouth.net Counsel for Plaintiff in Related Case No Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Fax Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Doe Epstein Page9 Bruce Reinhart Esq Bruce Reinhart P.A Australian Avenue Suite West Palm Beach FL Fax ecf brncereinhartlaw.com Counsel for Defendant Sarah Kellen Theodore Leopold Esq Spencer Kuvin Esq Ricci-Leopold P.A PGA Blvd Suite Palm Beach Gardens FL Fax Counsel for Plaintiff in Related Case No skuvin riccilaw.com tleopold riccilaw.com rjosefsberg podhurst.com kezell odhurst.com Counsel for Plaintiffs in Related Cases Nos and Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Fax jagesq beUsouth.net Counsel for Defendant Jeffrey Epstein Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of BURMAN CRITTON LUTTIBR COLEMAN LLP MlCRAfl l30RMAN OlUlOORYW OOU:MAN P.A ROBB!rr CIUTtO JJl I A.I l!RNARD l!Pl ER MA.RKT.LlTil:!!l.PA JE!F.lRllY ll:!PJN A UM!TfiO t.IAlLtrY PAJtTltERSHJP Mle!Wn PIKB ffBAlHBlt AMARA RUDA I OlUr,.,OMDCSlmlIW CIVlt UAI 1.AWYI!lt 247ent by MaiJ and U.S Mail Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Dear Bob May APl!tQVU A.ve PAl.llGIJ I JllYEStlOIITI I B..,IUIAM McKBNNA ASHUB S!Og:Q4-13AAIJ-IG fs not Mr Epsteins Intention to have direct contact with your clients It is unnecessary to respond point by point to statements attributed to my co counsel EXHIBIT_L SlS FLAGLER DRIVE SUITB I WEST PALM BBACH,FLORIDA l"BLBPHONB FAX mall bololaw.oom Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of May Page2 Rather than to be concerned about what my client Is doing I would ask that you advise your clients not to contact Mr Epsteins lawyers directly Neither I nor the attorneys who represent Mr Epstein want to be put In a position where we are set up by any of your clients RDC/mso cc Roy Black Esq Jay Lefkowitz Esq Michael Burman Esq Jack Goldberger Esq Josefsberg.011.C!Oc Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of MICHAEL BURMAN P.A OREOORY COLEMAN A ROBERTD.CJ:UTION,JR..,PA BERNARD LEBEDEKER MARKT LDrnER P.A JEFfRBY PEPlN A LIMITED LIABILITY PARTNBRSHlP MICHAELJ PIKE HEATHER McNAMARA RUDA lLOf A BOARD Cll!mfl CIVIL TRIAL LAWYE!t Katherine Ezell Esq Robert Josefsberg Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Re Dear Kathy and Bob May ADBl.QUI BENAVENTE PAR UlOAL I INVESTIGATOa BARBARA Mcl ENNA ASHLIE STOICBN-BARINO Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of May Page2 fugitive With the funds now under your control you must make your own decision on disbursement Finally as I also indicated In our telephone conversation your client contacted Jack Goldbergers office last week suggesting that Jack was holding up the settlement He did not speak with her I dont know where Ms got that idea RDC/clz cc Jack Goldberger Esq
