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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, INAND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2006CF009454A STATE OF FLORIDA Vs. JEFFREY EPSTEIN, Defendant. / RESPONSE TO MOTION FOR PROTECTIVE ORDER COMES NOW the Defendant, JEFFREY EPSTEIN, by and through his attorney and files his response to the Motion For Protective Order filed by counsel for State’s witness Jane Doe No. 1. 1. In summary fashion, counsel for Jane Doe No. 1 complains that serving a witness for deposition by the use of a process server and the service of the witness’ parents for the deposition to ensure service, amounts to “continuous and systematic harassment”. ' 2. The Motion For Protective Order was filed by one of the attorneys purporting to represent Jane Doe No. 1 in a separate civil proceeding.” While disagreeing with the ' Undersigned counsel for the Defendant responds only to the issues in the Motion for Protective Order concerning service of a subpoena for deposition and the date for that deposition. Defendant and undersigned counsel have no knowledge of any agent of the Defendant going to the witness’ place of employment representing “himself as an attorney who needed to contract (sp) her” as alleged “on information and belief” in paragraph 8 of the Motion for Protective Order. 2 The Motion for Protective Order was filed by attorney Theodore Leopold. While he purports to represent Jane Doe No.1, attorney Jeffrey Herman also claims to represent the interests of Jane Doe No. 1. In that separate civil proceeding, the two law firms are presently litigating who represents the interests of Jane Doe No. 1. 07/26/17 Page 28 Public Records Request No.: 17-295 DOJ-OGR-00031549