EFTA00728483.pdf

Case 9:08-cv-80119-KAM Document 547 Entered on FLSD Docket 05/17/2010 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, Vs. JEFFREY EPSTEIN, et al. CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON Defendant. / Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 / NOTICE OF SUPPLEMENTAL AUTHORITY ON PLAINTIFF JANE DOE'S MOTION FOR AN ORDER TO SHOW CAUSE AND FOR AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW fDE 4831 Plaintiff, Jane Doe, hereby gives notice of filing portions of the probation file of Defendant, Jeffrey Epstein, in connection with the above referenced Motion for Order to Show Cause and to Compel the Deposition of Jean Luc Brunel [DE 483]. On March 10, 2010 Plaintiff filed her Motion for an Order to Show Cause and for an Order to Compel [DE 483] requesting entry of an Order directed to Jean Luc Brunel and his counsel ordering them to show cause why they should not be held in contempt, for sanctions, and for an Order compelling Jean Luc Brunel to appear for deposition. Plaintiff's counsel recently obtained Epstein's probation file that contains documents that further corroborate Plaintiff's position that Brunel has not remained out EFTA00728483 Case 9:08-cv-80119-KAM Document 547 Entered on FLSD Docket 05/17/2010 Page 2 of 4 CASE NO: 08-CV-80119-MARRA/JOHNSON of the country as Brunel's counsel suggested, but has in fact been staying with Epstein much of 2010, if we are to believe the records Epstein provided to probation. The portions of the probation file, specifically the Written Monthly Reports from December 2009 through February 2010 are attached hereto as Exhibit "A." A section of the Written Monthly Report requires Defendant to "List full names, ages, and your relationship to all persons who resided at your residence this month" in the middle section of the form. Defendant identifies Jean Luc Brunel in his probation papers as residing with him within the period of December 2009 to February 2010, when Ms. Kudman represented him to be out of Florida. As indicated in our previous pleading, Mr. Brunel was served for deposition, and his counsel Ms. Kudman represented that she would produce him for deposition in Florida. She ultimately reneged, saying that her client told her that he was in France indefinitely and would not be returning to the United States, a representation known to be false. In an email dated January 25, 2010, Ms. Kudman responds to a request for dates for her client's deposition by writing, "I have just been informed that my client will be out of the country until the end of March." (Email attached here to as Exhibit "B") Again, while it is not believed that Ms. Kudman made the false representation intentionally, and it is more likely that Mr. Brunel simply made that false representation 2 EFTA00728484 Case 9:08-cv-80119-KAM Document 547 Entered on FLSD Docket 05/17/2010 Page 3 of 4 CASE NO: 08-CV-80119-MARRA/JOHNSON to his attorney, it is impossible for the undersigned to know with any degree of certainty exactly who participated in this plan to obstruct Jane Doe's discovery. As such, Plaintiff files her supplemental authority and requests the relief previously sought. DATED: May 17, 2010 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com and Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 17, 2010 I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing. s/ Bradley J. Edwards Bradley J. Edwards 3 EFTA00728485 Case 9:08-cv-80119-KAM Document 547 Entered on FLSD Docket 05/17/2010 Page 4 of 4 CASE NO: 08-CV-80119-MARRA/JOHNSON SERVICE LIST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. Jgoldberger@agwpa.com Robert D. Critton, Esq. rcritton@bciclaw.com Isidro Manual Garcia isidrogarcia@bellsouth.net Jack Patrick Hill iph@searcylaw.com Katherine Warthen Ezell KEzell@podhurst.com Michael James Pike MPike@bciclaw.com Paul G. Cassell cassellp@law.utah.edu Richard Horace Willits lawyerswillits@aol.com Robert C. Josefsberg rjosefsberg@podhurst.com Adam D. Horowitz ahorowitz@sexabuseattorney.com Stuart S. Mermelstein ssm@sexabuseattorney.com 4 EFTA00728486