EFTA00723088.pdf

MERMELSTEIN & HOROWITZPA ATTORNEYS AT LAW Adam D. Horow"dz Tel 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 wwvv.sexabuseattomey.com September 29, 2009 Via U.S. Mail Hon. Jeffrey Colbath Palm Beach County Circuit Court Criminal Division W Re: State of Florida v. Jeffrey Epstein Dear Judge Colbath: lam writing to you regarding Jeffrey Epstein as I understand you may be the presiding judge in his criminal case. My client, is one of Jeffrey Epstein's alleged victims. She has asked me to report to you that Jeffrey Epstein violated the terms of his probation, including his No-Contact Order, during an incident on September 16, 2009 in which Mr. Epstein came within approximately ten (10) feet of her, stared her down, and intimidated her to tears. This occurred at a time and place where Jeffrey Epstein knew he might come into contact with . An affidavit setting forth the facts is attached hereto. My client can testify to these events as well. If you require additional information from my client, please do not hesitate to ask. Respectfully submitted, EFTA00723088  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRAJJOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTELN, Defendant. Related Cases: 08-80232, 08-80380, 08.80381, 08-80994, 08-80993, 0840811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092, DECLARATION OF ADAM D. HOROWITZ 1. My name is Adam D. Horowitz. I am an attorney for Jane Doe No. 4. 2. The deposition of Jane Doe No. 4 was scheduled for September 16, 2009 at 1:00 p.m. at . 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 No. 4 (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 Doe No. 4 and 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 EFTA00723089 walking and began to stare at and intimidate Jane Doe No. 4. Jane Doe No. 4 was 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 12 2009 r:e 1 Main Horowitz 2 EFTA00723090