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é Case 9:08-cv-80119-KAM Document 305 Entered on FLSD Docket 09/17/2009 Page 2 of 8 3, The undersigned’s office began attempting to set the deposition of Jane Doe No. 4 / - on July 21, 2009. Because of the number of attorneys who would be attending (based on the | court’s consolidation order) coordinating the video deposition creates logistical problems. . 4. On August 27, 2009, the undersigned wrote a letter to counsel for the Plaintiff indicating that Mr. Epstein would be present at the deposition. A copy of that letter is attached as Exhibit 1. . 3, Some 13 days later, counsel for Jane Doe No. 4 filed a motion for protective order on September 9, 2009 attempting to prohibit Mr-Epstein’s presence at the deposition. The . Defendant immediately filed a response {an Emergency Motion) on September 11, 2009 requesting that the court enter an order allowing Epstein, the Defendant in this matter, to attend the deposition. This is commen procedure. See Exhibit 2, without exhibits. As of the date of the deposition, the court had not ruled on these motions. 6. On Monday, counsel for Jane Doe No. 4 and the undersigned spoke, an agreement _ Was reached that the deposition would proceed as scheduled, and that Mr. Epstein would not be 7 - in attendance other than by telephone or other means. See Exhibit 3. 7. The deposition was originally scheduled on the 15 Floor and moved by Prose to a larger. ground floor to accommodate the number of people who were to attend 8. ‘The undersigned and his partner, Mark T. Luttier, had scheduled a meeting with Mr. Epstein for approximately an hour prior to the deposition. It is well known through multiple newspaper articles that Mr. Epstein’s office at the Florida Science Foundation is located on the , ccd Floor in the same building as the court reporter and Mr. Epstein’s criminal atiommey, Mr. i “Goldberger. As well, had the court issued an order prior to the deposition that would have allowed Mr, Epstein to attend, he was readily available. 2 03956-10986.“ - DOJ-OGR- 00030274