Jane Does v. Epstein

From reviewing the transcripts, it seems Dr. Kliman utilized Questionnaire's with all of your clients. I need them. Please advise of your position. I'm sure you will produce since they are discoverable. Thanks.

Gentlemen:

I sent the e-mail below weeks ago. I have not heard back from you. I'm entitled to the questionnaires Kliman had your clients fill out and which he utilized to formulate his opinions. I need them by tomorrow since they are well over due. If not, I will have no other choice to file a motion, which I do not want to do given how we have worked together on these issues in the past. Let me know, pike.

Please allow this to conform that Jeffrey Epstein will not attend tomorrow's deposition of Jane Doe No. 4 (In the absence of a Court order permitting him to attend). We understand you may wish to have your client listen in by telephone or view a videofeed of the deposition, but will not be seen by our dent.

Regards,

Adam D. Horowitz, Esq.
www.sexabuseattorney.com
Mermelstein & Horowitz, P.A.
18205 Biscayne Boulevard
Suite 2218
Miami, FL 33160
ahorowitz@sexabuseattorney.com
Tel: (305) 931-2200
Fax: (305) 931-0877