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YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 After the filing of the civil lawsuit and during the week of January Epsteins criminal attorney Jack Goldberger Esq contacted the undersigned to advise that he wished to take the deposition in the criminal matter of Jane Doe on February The undersigned informed Mr Goldberger that he would accept service on behalf of Jane Doe but was not available on February Counsel agreed to use best efforts to schedule the deposition at a mutually convenient date and time Despite these assurances and understanding on Friday evening February Epsteins process server served Jane Doe at her place of work for a deposition scheduled to take place on February See Subpeona attached as Exhibit A Jane Does real name has been redacted from the exhibit The undersigned was forced to call Mr Goldberger on Friday evening and remind him of our earlier conversation and agreement and to insist that the deposition be re-noticed After the conversation of Friday evening and with the expressed assurances that the undersigned would accept service for Jane Doe two days later on Monday morning February Mr Goldberger had a process server serye Jane Does mother who resides out of state in Waleska Georgia See Subpoena attached as Exhibit Jane Does mothers name has been redacted from the exhibit The service of process on Jane Does mother was defective as an Out of State Commissioner was never appointed and no order was issued by this court authorizing such service Additionally Mr Goldberger had been told not once but twice that the undersign would accept service on behalf of Jane Doe yet despite this Epstein and/or his attorney has insisted on Mr Goldberger unilaterally set Jane Does deposition for February despite knowing that the undersigned was not available on that date Mr Goldberger has now agreed to postpone the deposition Page of having the victims privacy repeatedly intruded upon by process servers seeking her out at her employment and then again intruding upon her mother Additionally during this same time period yet another adult male came to Jane Does employment and represented himself as an attorney who needed to contract her Upon information and belief that person was also an agent of Mr Epsteins It can only be concluded that Epstein and/or his counsel are purposefully attempting to harass Jane Doe and her mother These actions are nothing more than a continuous insult to injury upon a young girl who has already been emotionally scarred for life WHEREFORE Jane Doe by and through Jane Does mother and natural guardian hereby move the Court for a Protective Order prohibiting Jeffrey Epstein and/or his counsel from continuous and systematic harassment I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by Facsimile and U.S Mail postage prepaid this_ day of February to all counsel on the attached service list Respectfully submitted RICCl LEOPOLD P.A PGA Blvd PalmB Phone Page of D,Esq State of Florida Jeffrey Epstein Case No SERVICE LIST Lanna Belohlavek Esq Attorney For Party Dixie Highway West Palm Beach FL Phone Fax Jack A Goldberger Esq Attorney For Jeffrey Epstein Australian A venue Suite West Palm Beach FL Phone Fax AM MYERS STATE OF FLORIDA VS JEFFREY EPSTEIN Defendant TO IN THE e;ReUIT COURT OF THE FIFTEEN"frr JUDICIAL CIRCUIT IN ANO FOR PALM BEACH COUNTY FLORIDA CASE NO SUBPQl;NA FOB DEPOSITION YOU ARE COMMANDED to appear before a person authorized by law to take depositions on the 4th floor Rooms of the Palm Beach County Courthouse North Dixie Highway West Palm Beach Florida on February at a.m for the taking of your deposition in this action If you fail to appear you may be In contempt of court You ere subpoenaed to appear by the following attorneys and unless excused from this subpoena by these attorneys or the Court you shall respond to this subpoena as directed WITNESS my hand and seal of said Court on this day of January Ja A old rger ESQ Fo he Court Australian Avenue South Suite est Palm Beach Florida __ FAX ERA SUNRISE REALTY STATE OF FLORIDA vs JEFFREY EPSTEIN Defendant __ TO IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SUBPOENA FOR DEPOSITION YOU ARE COMMANDED to appear before a person authorized by law to take depositions on the 4th floor Rooms of the Palm Beach County Courthouse North Dixie Highway West Palm Beach Florida on February starting at a.m for the taking of your deposition..iaJhis action fLY_.e,,u fi!il to appe __ you may be 1n contempt of court You are subpoenaed to appear by the following attorneys and unless excused from this subpoena by these attorneys or the Court you shall respond to this subpoena as directed WITNESS my hand and seal of said Court on this st day of February Goldoerger SQ Court Australian Avenue South Suite est Palm Beach Florida
