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3. After the filing of the civil lawsuit and during the week of January 25, 2008, Epstein’s criminal attorney, Jack Goldberger, Esq., contacted the undersigned to advise that he wished to take the deposition, in the criminal matter, of Jane Doe on February 6, 2008. The undersigned informed Mr. Goldberger that he would accept service on behalf of Jane Doe, but was not available on February 6, 2008. Counsel agreed to use best efforts to schedule the deposition at a mutually convenient date and time. 4. Despite these assurances and understanding, on Friday evening, February 1, 2008, Epstein’s process server served Jane Doe at her place of work for a deposition scheduled to take place on February 6, 2008. ' See Subpeona attached as Exhibit “A” (Jane Doe’s real name has been redacted from the exhibit). a The undersigned was forced to call Mr. Goldberger on Friday evening and remind him of our earlier conversation and agreement and to insist that the deposition be re-noticed.’ 6. After the conversation of Friday evening and with the expressed assurances that the undersigned would accept service for Jane Doe, two days later on Monday morning February 4, 2008, Mr. Goldberger had a process server serve Jane Doe’s mother who resides out of state in Po See Subpoena attached as Exhibit “B” (Jane Doe’s mother’s name has been redacted from the exhibit). i. The service of process on Jane Doe’s mother was defective as an Out of State Commissioner was never appointed and no order was issued by this court authorizing such service. Additionally, Mr. Goldberger had been told not once, but twice that the undersign would accept service on behalf of Jane Doe, yet despite this Epstein and/or his attorney has insisted on ' Mr. Goldberger unilaterally set Jane Doe’s deposition for February 6, 2008 despite knowing that the undersigned was not available on that date. ? Mr. Goldberger has now agreed to postpone the deposition. 07/26/17 Page 2eof 3 Public Records Request No.: 17-295 DOJ-OGR-00031557