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Case 9:08-cv-80119-KAM Document305-3 Entered on FLSD Docket 09/17/2009 Page 2 of 11 Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 2 of 33 Page 2 2. Additionally, notices were sent out in other cases in connection with deposing additional Plaintiffs. 3. No objection(s) was/were received for Jane Doe No. 4, which was the only deposition set relative to the Jane Doe 2-8 Plaintiffs. 4, On August 27, 2009, the undersigned counsel sent a letter to counsel for Jane Doe No. 4 conceming her deposition and the scheduling of same on the above date. See Exhibit “2”. 5. No response was received until counsel for Jane Doe No. 4 called on September 8, 2009, approximately. eight days prior to the scheduled deposition, to indicate that they now had an objection and would be filing a motion for protective order seeking to prevent Epstein from attending the deposition. Once again, Plaintiffs are attempting to stifle this litigation through their own delay tactics during discovery. Plaintiffs wish not only to attempt to force Epstein to trial without any meaningful discovery, but now wish to ban Epstein from any depositions, thereby preventing him from assisting his attorneys in his very own defense. What’s next — will Plaintiffs seek to prevent Epstein from attending any of the trials that result from the lawsuits Jane Does 2-8 have initiated? Plaintiffs see millions of dollars in damages, both compensatory and punitive, against Defendant. 6. Defendant is filing this emergency motion and his immediate response to the motion for protective order to guarantee his right to be present and assist counsel in deposing not only Jane Doe No. 4, but other plaintiffs and witnesses in these cases. To hold otherwise would violate Epstein’s due process rights to defend the very allegations Plaintiffs have alleged against him. Does a Defendant not have a right to be present at depositions or other court proceedings to ‘assist counsel with the defense of his case? Does a Defendant, no matter what the charges or the allegations, have full and unbridled access to the court system and the proceedings it governs, 03956-10995