UNITED DISTRICT COURT-4.8 SOUTHE-3.1RN DISTRICT OF FLORIDA JANE CAS-3.5E NO 93-CIV-MARRA/JOHNSON Plaintiff Vs JEFFREY EPST-4.5EIN et al Defendant Related Cases PLAINTIFF-5.1 JANE TO DEFE-3.9NDANT?S MOTION FOR A PROTECTIVE ORDER DE Plaintiff Jane Doe hereby files re sponse to Defendant Ep st-6.5ein?s Motion for A Protectiv-5.2e1 Order Regarding the Deposit-7.6ion of Stor-7.4y Cowles The motion should be denied in its entir ety as Cowles possess-5.3es non-priv-5.6ileged information any true attorney-client information he possesses obvious-5.5ly need not be disclose-9.3d-4.3 during his deposition 2700Plaintiff Jane Doe agrees that Story Co who was hired by Epstein?s defe-3.8n1.3se attorney in pos-5.5sesses some information prop-4.2erly covered by the attorney-clie-4.2nt privilege and by work product For example defense counsel may have asked Cowles to relay attorney-client advice to Epstein Jane Doe does not intend to ask any questions regarding attorney client advice during Cowles?s deposition Case Document Entered on FLSD Docket Page of CASE NO the same time however Cowles possesses significant information about statements made by Ep stein that are clearly and obv-5.2iously not c-5.2o1vered by the attorney client or any other privilege In particular Cowles visi ted Epstein times between and while Epstein was inc-5.3a.9rcerated here he has been listed as a Paralegal an Attorney and Public Defender on different occasions See Affidavit of Bradley Edwards attached as Exhibit A Often these visits-5.7 with Epst-7.9ein three people Epstein,-7.4 Cowles and a third-party visitor who not part of Epstein?s legal defense team eit her civil or criminal Of cour se the presence of a third-party-5.4 eliminated any confidentia lity that might otherwise have attached to discussions between Cowles and Epstein See id Cowles affidavit that has been filed Epstein states charily that Epstein has never discussed the asserted against him except in the presence of an attorney Cowles Affidavit Ex to Epstein?s Motion at emphasis added But there are a variet-7.5y of other subjec ts apart from the claims asse rted against him that Epstein-8.7 likely disc-5.3ussed either with Cowles or with third party vi sitors in the p-4.4r-2.5esence Cowles For example Epstein may have di scussed where he is hiding his assets with Cowles Is he moving them to the Channel Islands as Jane Does has heard Is he moving them to Israel as has been suggest-7.9ed in a nationally-circula ted public-5.5ation Is he liquidating them to pay mounting bills he transferring title to his expensive cars-5.3 and yachts-5.2 to other persons as Jane Doe ar gued in her motion seeking to block further-6.9 asset trans5fers Case Document Entered on FLSD Docket Page of CASE NO 2560Another subject that Jane Doe plans to exp-4.1l2ore Cowles has been in a dating relationship with Sarah Kellen for more than a year As the Court is aware Jane Doe has alleged that Sarah Kellen conspired wit-7.8h Epstein to se xually abuse her Kelle-4.8n has taken the Fifth rather than ans-5.2wer questions about her role in helping Epstein abuse Jane Doe and other girls Jane Doe is obvious-5.6ly entitled to explore thes-5.1e subjects during a deposition of Cowles It simply defie any believability to think that Cowles will attempt to maintain under oath that not once has he discussed with his girlfriend anything c-5.3onnected either directly or indirectly with Epstein?s activities At the very least Cowles should be required to make w6.9hat ever representations he intends to make on this subject under oath at a deposition.-7.6 2644.3Another subject that Jane Doe plans to ex plore is Cowles?s rrands that recently been running for Epst ein Mr Cowles?s primar-7y owned Defendant-8.3 Epstein which clearly indicates-5.5 a relationshi quite different from that a client-8.3 paralegal Jane Doe under stands that Cowles is cur-7.4r-2.4ently at Epstein?s home nearly every day and works directly for Epstein I-7.3ndeed Cowles has r-7.1epresented himself to Florida probation authorities Epstein?s-5.1 assistant See Affidavit of Bradley Edwards attached as Exhibit A Cert ainly in this-5.5 capacity Co wles has personally observed and communicated with the visitors that come and go from Epstein?s home all potential-8.2 witnesses Here again ther is ample ground for ques-5.5tioning on subjects not remotely-4.7 covered by any kind of privilege.-7.7 Case Document Entered on FLSD Docket Page of CASE NO another example of relevant subjects not covered by any privilege that Jane Doe plans-5.8 to explore Epstein may have disc-5.1ussed plan-4s to fl ee the jurisdictio-3.7n1.4 to being serv-5.6ed with legal process connected with the case sum all of these subjects not to mention many others are obvious-5.6ly not covered any attorney client pr-7.5ivilege and a depos ition of Cowles inquiring into subjects is clearly proper 2623.4Epstein argues t-7.8hat Jane Doe?s co uns-4.9el agreed?-6.9 apparently forever and for all subjects and for all time never to depose Cowles While there was a limited agreement regarding Cowles Epst ein?s des-5.7cription of what wa agreed goes-5 far beyond-8.8 what was actually agreed See Affidavit of Bradley Edwards attached as Exh-4.1i2bit A Here again there is no basis for the Court fo reclosing all opportunity to question Cowles-5.3 about his potentially important knowledge regarding Epstein and recent efforts to hide ass-5e1.2ts and other activities This point is even more important given the fact that-7.8 Epstein and all of his known co-c-5.5onspirators in his child molestation ring namely Sarah Kellen Nadia Marcinkova and Adriana Mucinska have inv)-5o1.2ked their th amendment-7 rights against self-incrimination and have hus stopped Plaintiff from gaining meaningful discovery whatsoever-7.1 all these reasons Epstein?s-5.5 motion to foreclose completely a deposition of Cowles should be denied Obvious-5.6ly ane Doe will not ask questions during the deposition about attorney-client advice conv-5.5eyed by Cowles to Case Document Entered on FLSD Docket Page of CASE NO DATED May Respectfully Submitted Bradley Edwards Bradley Edwards-5.3 FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN P.L North Andrews Avenue Suit-7.8e Fort Lauderdale Florida Telephone Facsimile Florida No E-mail brad pathtojustice.com and Salt 2720Lake 2720City Telephone:-7.7 Facsimile:-7.7 E-Mail 110cassellp law.utah.edu CERTIFICATE OF SERVICE HEREBY CERTIFY that on May I electronically filed the foregoing document with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all part ies on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF or in some ot-6.9her authorized manner fo those parties who are not authorized receive electronically filed Notices of Electronic Filing.-7.5 Bradley Edwards Bradley Edwards-5.3 Case Document Entered on FLSD Docket Page of CASE NO SERVICE LIST Jane Doe Jeffrey10.8 Epstein United States District Court Southern District of Florida Jack Alan Goldberger-7.7 Esq Jgoldberger agwpa.c-5.1o1.1m Robert Critton Esq rcritton bclcla-4.3w.com Isidro Manual Garcia isidrogarcia bells-5.2outh.net Jack Patrick Hill jph searcylaw.com Katherine Warthen Ezell KEzell podhurst.com Michael James Pike MPike bclclaw.com Paul Cassell cassellp law.utah.edu Richard Ho-4.5race Willits-5.7 lawyerswillits aol.com Robert Josefsberg rjosefsberg podhurst.com Adam Horowitz ahorowitz-5.6 5sexabus-5.6eattorney.com Stuart Mermelstein-4.1 ssm sexabuseattorney.com Case Document Entered on FLSD Docket Page of
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