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 NOTICE OF SUPPL-5E-3.8M-2.8ENTAL AUTHORI-8TY ON PLAINTIFF JANE MOTION FOR AN ORDE-3.7R TO SHOW CAUSE A ND FOR AN ORDE-4.6R TO COMPEL AND INCORPORATED MEMORANDUM OF LAW DE 2605Plaintiff Jane Doe hereby gives notice filing portions of the probation file Defendant Jeffrey Epstein in connection wit the above referenced Motion for Order to Show Caus-5.6e and to Compel the Depos ition of Jean Luc Brunel DE March Plaintiff filed her Mo tion for an Order to Show Cause-4.1 and for an Order to Compel requesting entr of an Order directed to Jean Luc Brunel and his counsel order-7.7ing them to show caus-5.7e why they should be held in contempt for sanctions and for an Order compelling ean Luc Brunel to appear for deposition 2210Plaintiff?s counsel r-7.5e.7cently obtained Ep stein?s probation ile that contains-5.3 documents that further corroborat Plaintiff?s position t-7.5hat Brunel has not remained out Case Document Entered on FLSD Docket Page of CASE NO of the country as Brunel?s couns-5.5el suggested but has fact been staying with Epstein much of if we are to believe the records Epstein provided to probation portions of the probation file specif ically the Written Monthly Reports from December through February are attached hereto as Ex hibit A A section the Written Monthly Report requires De fendant to List full names ages and your relationship to all persons who resided at your residence this month in the middle section of the form 2704.2Defendant identifies J-5.8ean Luc Br-7.8unel in hi probation papers as residing with within the period of December to Fe bruary when Ms Kudman r-6.8epresented him to be out of Florida indicated in our pr-7.3evious pleading Mr Brunel was served for deposition and his counsel Ms Kudman represented that he would produce him for depositio-4.3n.8 in Florida ultimately reneged sa ying that her c-4.6lient told her that he was in France indefinitely and would not be returning to the United Stat es a representation known to be false an email dated January Ms Kudman responds to a request for dates-5 for her client?s deposit-7.6ion by writing I hav just been informed that my client will be of the country until the end of March Email attached here to as E7x5hibit 2570Again while it is not believed that Ms Kudman made the false representation intentionally and it is more likely-5.1 that Mr simply made that false representation Case Document Entered on FLSD Docket Page of CASE NO to his attorney it is impossible for the undersigned to k-5.7now with any degree of certainty exactly who participated in this pl an to obstruct Jane Doe?s discov-5.6e.6ry such Plaintiff files her supplem ental authority and re quests the previously sought DATED May Respectfully 2720Submitted 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 2720cassellp 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-4.9o1.3m Robert Critton Esq rcritton bclcla-4.1w.com Isidro Manual Garcia isidrogarcia bells-5.1outh.net Jack Patrick Hill iph searc-5.4y-.4law.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-5.5 4sexabus-5.5eattorney.com Stuart Mermelstein-4.1 ssm sexabuseattorney.com Case Document Entered on FLSD Docket Page of
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