DOJ-OGR-00030293.tif

41.2 KB

Extraction Summary

10
People
1
Organizations
2
Locations
1
Events
5
Relationships
3
Quotes

Document Information

Type: Email correspondence / court document
File Size: 41.2 KB
Summary

This document contains a series of emails from September and August 2009 related to the 'Jane Does v. Epstein' case. Key events include confirmation that Jeffrey Epstein will not attend Jane Doe No. 4's deposition and requests by Michael J. Pike for Dr. Kliman's client questionnaires, threatening to file a motion if they are not provided promptly.

People (10)

Name Role Context
Robert D. Critton Jr. Recipient/CC
Recipient of email from Adam Horowitz; CC of email from Michael J. Pike
Adam Horowitz Sender/Recipient
Sender of first email; Recipient of second email; listed with Mermelstein & Horowitz, P.A.
Michael J. Pike Recipient/Sender
Recipient of email from Adam Horowitz; Sender of second and third emails
Stuart Mermelstein CC/Recipient
CC of email from Adam Horowitz; Recipient of second and third emails; listed with Mermelstein & Horowitz, P.A.
Jeffrey Epstein Subject of deposition
Will not attend deposition of Jane Doe No. 4
Jane Doe No. 4 Deponent
Subject of deposition Jeffrey Epstein will not attend
Jessica Cadweli CC
CC of second email from Michael J. Pike
Dr. Kliman Expert
Utilized questionnaires from clients to formulate opinions
Ashlie Stoken-Baring Recipient
Recipient of third email from Michael J. Pike
Connie Zaguirre Recipient
Recipient of third email from Michael J. Pike

Organizations (1)

Name Type Context
Mermelstein & Horowitz, P.A.
Law firm of Adam D. Horowitz and Stuart Mermelstein

Timeline (1 events)

2009-09-16
Deposition of Jane Doe No. 4, which Jeffrey Epstein will not attend.

Locations (2)

Location Context
Business address for Mermelstein & Horowitz, P.A.
Address for Mermelstein & Horowitz, P.A.

Relationships (5)

Adam Horowitz colleagues/partners Stuart Mermelstein
Both listed with Mermelstein & Horowitz, P.A.
Michael J. Pike correspondents/involved in same case Robert D. Critton Jr.
Pike emails Critton Jr. directly and CCs him.
Michael J. Pike correspondents/involved in same case Adam Horowitz
Pike emails Horowitz, and Horowitz emails Pike.
Jeffrey Epstein litigant/deponent Jane Doe No. 4
Epstein is the subject of the 'Jane Does v. Epstein' case, and Jane Doe No. 4 is a deponent.
Dr. Kliman expert witness/clients Michael J. Pike's clients
Dr. Kliman utilized questionnaires from Pike's clients for his opinions.

Key Quotes (3)

"Please allow this to confirm 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 client."
Source
DOJ-OGR-00030293.tif
Quote #1
"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."
Source
DOJ-OGR-00030293.tif
Quote #2
"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"
Source
DOJ-OGR-00030293.tif
Quote #3

Full Extracted Text

Complete text extracted from the document (1,853 characters)

?
Case 9:08-cv-80119-KAM Document 305-4 Entered on FLSD Docket 09/17/2009 Pagle of of 2
Robert D. Critton Jr.
From: Adam Horowitz [ahorowitz@sexabuseattomey.com]
Tuesday, September 15, 2009 11:43 AM
Michael J. Pike; Robert D. Critton Jr.
Sent:
To:
Cc: Stuart Mermelstein
Subject: Jane Does v. Epstein
Please allow this to confirm 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 client.
Regards,
Adam D. Horowitz, Esq.
www.sexabuseattorney.com
Mermelstein & Horowitz, P.Α.
18205 Biscayne Boulevard
Suite 2218
Miami, FL 33160
ahorowitz@sexabuseattorney.com
Tel: (305) 931-2200
Fax: (305) 931-0877
From: Michael J. Pike [mailto:MPike@bclclaw.com]
Sent: Tuesday, September 15, 2009 10:54 AM
To: Stuart Mermelstein; Adam Horowitz
Cc: Robert D. Critton Jr.; Jessica Cadweli
Subject: FW: Jane Does v. Epstein
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.
From: Michael J. Pike
Sent: Tuesday, August 18, 2009 11:37 AM
To: Robert D. Critton Jr.; Stuart Mermelstein; Ashlie Stoken-Baring; Connie Zaguirre
Subject: 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
9/15/2009
EXHIBIT 3
03956-11005
DOJ-OGR-00030293

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