📧 Communication

This document is a Motion for Sanctions filed by Plaintiff Jane Doe No. 4 against Jeffrey Epstein for violating a no-contact order and a written stipulation. On September 16, 2009, Epstein appeared in the lobby of the building where Jane Doe No. 4's deposition was scheduled, staring her down and causing her to flee in distress, despite an agreement that he would not attend. The document includes a declaration from attorney Adam Horowitz, a transcript of the cancelled deposition where defense counsel Robert Critton argues Epstein was simply leaving his office in the same building, and an email confirming the prior stipulation.