Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80119-CIV-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I Related cases I PLAINTIFF CAROLYN Case Document Entered on FLSD Docket Page of of Plaintiffs And Incorporated Memorandum of Law Case No D.E and Plaintiff Jane Doe has filed her Motion For a Protective Order Enforcing No Contact Order and Incorporated Memorandum of Law Case No D.E Essentially these motions for protective orders seek to prevent Plaintiffs from suffering further victimization harm and mental trauma by having Jeffrey Epstein present in the room during their depositions while they recount the most intimate details of their lives including the sexual offenses committed against them by Jeffrey Epstein while they were minors Plaintiffs propose having a video feed linked to a monitor in another room where Mr Epstein can view same and have contemporaneous contact with his attorneys in the deposition room Plaintiff Carolyn Margaret Andrianos deposition has been set for October Based on correspondence received from counsel for Mr Epstein it is Mr Epsteins intention to be physically present in the room during Plaintiffs deposition Plaintiff Carolyn Margaret Andriano joins incorporates by reference and adopts the arguments made in support of Plaintiffs Jane Doe D.E and Jane Does D.E as if fully set forth herein Additionally as this Court is already aware the deposition of Jane Doe had to be cancelled after she encountered Mr Epstein in the lobby immediately adjacent to the deposition room notwithstanding the apparent agreement of counsel for Mr Epstein that he would not be present for same Plaintiff respectfully suggests that the requested protective order seeks to prevent Plaintiff from suffering from the Case Document Entered on FLSD Docket Page of psychological trauma as a result of a similar encounter with Jeffrey Epstein at her deposition Lastly it appears that Judge Hafele in a pending state court case Jeffrey Epstein Palm Beach County Circuit Court Case No has agreed that allowing Defendant to view a live video feed rather than be physically present in the deposition room was an appropriate balance between the parties interests See Jane Doe Nos Response to Emergency Motion to Strike Plaintiffs Motion for Protective Order and Emergency Motion to Allow the Attendance of Jeffery Epstein at the Deposition of Plaintiff D.E paragraph While Judge Hafeles determination is certainly not binding on this Court it is illustrative WHEREFORE Plaintiff Carolyn Margaret Andriano respectfully requests that this Court enter a protective order preventing Defendant Jeffrey Epstein from attending the deposition of Plaintiff Carolyn Margaret Andriano but permitting him to view a live video feed of the deposition from a remote location CERTIFICATE OF COMPLIANCE WITH LOCAL RULE Counsel for the movant has conferred with counsel for the Defendant regarding his position on the instant motion and has been informed that counsel for Defendant is not in agreement with any of the relief requested herein Isl Jack Hill Case Document Entered on FLSD Docket Page of CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 29th day of September I electronically filed the foregoing with the Clerk of the Court by using CM/ECF system which will send a notice of electronic filing to all counsel of record on the attached service list sllack Hill Jack Scarola Florida Bar No Jack Hill Florida Bar No Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Plaintiff Case Document Entered on FLSD Docket Page of Richard Willits Esquire Richard Willits P.A 10th Avenue North Suite Lake Worth FL reelrhw hotmail.com Robert Critton Esquire Michael Pike Esquire Burman Critton Luttier Coleman LLP North Flagler Drive Suite West Palm Beach FL rcrit bclclaw.com mpike bclclaw.com Jack A Goldberger Esquire Atterbury Goldberger Weiss P.A Australian Avenue South West Palm Beach FL jagesq bellsouth.net Bruce Reinhart Esquire Bruce Reinhart P.A South Australian Ave Suite West Palm Beach FL ecf brucereinhartlaw.com Stuart Mermelstein Esquire Adam Horowitz Esquire Mermelstein Horowitz P.A Biscayne Blvd Suite Miami FL ssm sexabuseattorney.com ahorowitz sexabuseattorney.com Brad Edwards Esquire Rothstein Rosenfeldt Adler East Las Olas Blvd Suite Fort Lauderdale FL bedwards rra-law.com Paul Cassell Esquire Pro Hae Vice South Room Salt Lake City UT cassellp law.utah.edu COUNSEL LIST Case Document Entered on FLSD Docket Page of Isidro Garcia Esquire Garcia Law Firm P.A Datura Street Suite West Palm Beach FL isidrogarcia bellsouth.net Robert Josefsberg Esquire Katherine Ezell Esquire Podhurst Orseck P.A West Flagler Street Suite Miami FL rjosefsberg pod hu rst.com kezell pod hurst com
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