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Case 9:08-cv-80119-KAM Document 305-3 Entered on FLSD Docket 09/17/2009 Page7of 11 Case 9:08-cv-80119-KAM Document296 Entered on FLSD Docket 69/11/2009 Page? of 33 Page 7 Dd. Spoke with two psychiatrists when she was sixteen or seventeen (before this lawsuitl} and did not reference Epstein, but did reference her boyfriend and family issues. 17. There are police reports that reflect that: A. In September 2004, a battery report was filed regarding Jane Doe No. 4 and Vinyard based on au argument where he grabbed her by the neck and began spitting on her and calling her a cheater. B. Also in September 2004, there was a domestic violence file opened where Vinyard was physically and verbally abusive to Jane Doe No. 4, his girlfriend at the time. There is reference that the two started a serious relationship in January 2002, when she was only fourteen (14) years oid. on Vinyard was arrested in December 2003, and charged with reckless driving and leaving the scene of the accident with Jane Doe No. 4, when their vehicle hit a tree and they fled. 48, Moreover, an ex-boyfriend of Jane Doe No. 4 died in a DUI accident and it took her two years to get over his death, and another good friend of hers, “Jen,” died in an automobile accident involving drinking. Within her Amended Complaint and Answers to Interrogatories, she indicates that she vent to Epstein’s house on several occasions. However, at no time did she call the police, at no time did she report any traumatic or severe emotional trauma, nor alleged coercion, force or improper behavior by Epstein until she got a “lawyer” and is now pursuing claims for millions of dollars, Epstein’s assistance to his attorneys at these depositions regarding the above issues is not only a constifutional due process right afforded to him but essential given the fact that this court has ruled that Plaintiffs’ depositions can gnly occur one time, no “second | bife” absent a court order. 19. Given the breadth of the allegations made against Epstein and the substantial damages sought, Epsiein has an unequivocal and constitutional right to be present at any deposition such that he can assist his counsel with the defense of these cases. See infra. Dr. Hall . 03956-11000 DOJ-OGR- 00030288