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Case 9:08-cv-80119-KAM Document305 Entered on FLSD Docket 09/17/2009 Page 6of8 Rule 7.1 A. 3. Certification of Pre-Filing Conference Counsel for Defendant conferred with Counsel for Plaintiff by telephone and by e-mail; however, an agreement has not been reached. WHEREFORE, Defendant moves this court for an order granting sanctions to include attorneys fees and costs as set forth above and costs associated with the attendance of the court reporter, the transcript and the presence of the videographer and direction that Jane Doe No. 4 appear for deposition within fifteen (15) days from the date of the court’s order at the court reporter’s office. If the court has not issued an order regarding Mr. Epstein’s attendance at Plaintiff's deposition when Jane Doe No. 4 is to appear, the Defendant will agree that Mr. Epstein will not be present in the building on the date of her scheduled deposition such that no “inadvertent” contact will occur. Robert PB. Critton, Jr. Michaél J. Pike Attorneys for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was hand-delivered to the Clerk of the Court as required by the Local Rules of the Southern District of Florida and electronically mailed to all counsel of record identified on the following Service List on this [ al day of September, 2009. Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON 03956-10990