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efta-02728774DOJ Data Set 11Other

EFTA02728774

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DOJ Data Set 11
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efta-02728774
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2
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08.CV-80119-MARRAIJOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591. 09-80656, 09-80802, 09-81092, p.m. a DECLARATION OF ADAM D. HOROWITZ 1. My name is Adam D. Horowitz. l am an attorney for Jane Doe 2. The deposition of Jane Doe =vas scheduled for September 16, 2009 at 1:00 On the day before the deposition, the undersigned and counsel for Jeffrey Epstein entered into a written stipulation in which it was agreed that "Jeffrey Epstein will not attend tomorrow's deposition of Jane Doe. El(in the absence of a court order permitting him to attend)." It was further agreed that Jeffrey Epstein may listen in to the deposition by telephone or view a videofeed of the deposition, but under no circumstances would he "be seen by our client." 3. While Jane DoeMind I were in the lobby of approximately 1:00 p.m. for her deposition on September 16, 2009, we crossed paths with Jeffrey Epstein and someone who appeared to be his bodyguard. Jeffrey Epstein stopped 09/1212019 EXHIBIT I A CONFIDENTIAL Agency to Agency Requet 19-411 SDNY_GM_00330126 EFTA 00202852 EFTA02728774 walking and began to stare at and intimidate Jane Doe Jane Davas terrified, began crying and ran outside the building. Jeffrey Epstein smirked at her and walked away. 4. As a result of this incident, Jane Doe began crying uncontrollably and was unable to proceed with her deposition. Under penalties of perjury I declare that I have read the foregoing Declaration and the facts stated in it are true. Dated: September /7 2009 09112/2019 0 —Ali Adam D. Horowitz 2 Pape 97 CONFIDENTIAL Agency to Agency Requet 19-411 SDNY_GM_00330127 EFTA 00202853 EFTA02728775

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Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372112011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater

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