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Case 9:08-cv-80119-KAM Document 305-3 Entered on FLSD Docket 09/17/2009 Page 3of11 Case 9:08-cv-80119-KAM Dosument296 Entered on FLSD Docket 09/11/2009 Page 3 of 33 Page 3 including discovery? The short answer is unequivocally, yes. To hold otherwise would be a direct violation of Epstein’s constitutional due process rights. Plaintiffs’ atfempts to play fast and loose with the law should not be tolerated. ¢. As the court is aware, plaintiffs and defendants routinely attend depositions of parties and other witnesses in both State and Federal court proceedings. In fact, parties have a right under the law to attend such depositions. 8. _ As the court will note from Exhibit 2, counsel for the Defendant specifically stated that “Please be advised that Mr. Epstein plans to be in attendance at the deposition of your client. He does not intend to engage in any conversation with your client. However, it is certainly his right as a party-defendant in the lawsuit to be present ard to assist counsel in the defense of any case.” Despite this right, Plaintiffs continue to attempt to control how discovery is conducted in this case and how this court has historically governed discovery. 9. Interestingly, in Jane Doe If, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is despite her claims of “emotional trauma” set forth in her complaint. Jane Doe No. ¥ is also a Plaintiff in the federal court proceeding Jane Doe ily. Jeffrey Epstein (Case No. 09-CIV- 80469). Is this court going to start a precedent where it allows Plaintiffs to attend the depositions of Jeffrey Epstein, but not allow Epstein to attend their depositions (i.¢., the very Plaintiffs that have asserted claims against him for millions of dollars)? This court should not condone such a practice. 40. The undersigned is well aware of the court’s No-Contact Order entered on July 31, 2009 (DE 238). A copy of the order is attached as Exhibit “3”. In fact, the order provides that the defendant have no direct or indirect contact with the plaintiffs, nor communications with 03956-10996 DOJ-OGR- 00030284