File 033503

Email Chain Regarding Jane Doe Deposition and Discovery Matters (File 033503)

August 2009 email correspondence between attorneys at Burman Critton Luttier & Coleman regarding deposition scheduling, discovery responses, and witness coordination in a case involving Jane Doe.

Summary

This email chain from August 6-11, 2009 documents attorney communications at the law firm Burman Critton Luttier & Coleman regarding litigation involving Jane Doe. The correspondence addresses deposition scheduling for Jeffrey Epstein and Ghislaine Maxwell, discovery responses (ROGs), obtaining records from the Department of Juvenile Justice regarding Milton Center for girls, and an emergency protective order filed by an unnamed party. Key discussions include rescheduling Maxwell's deposition from August 17 to September 23, confirming Epstein's deposition date, and coordinating on HIPAA releases needed to obtain juvenile justice facility records.

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From: Jeffrey Epstein [jeeyacation@gmail.com]
Sent: 8/11/2009 7:00:57 PM
To: Jessica Cadwell
Subject: Re: FW: Jane Doe
Privileged - Redacted
On Tue, Aug 11, 2009 at 2:55 PM, Jessica Cadwell > wrote:
Privileged - Redacted
frJaca &dazeEE e9), Yccia'
Certified Paralegal
Florida Registered Paralegal
BURMAN CRITTON LUTTIER & COLEMAN, LLP
515 N. Flagler Drive
Suite #400
West Palm Beach, FL 33401
From: Jacquie Johnson [mailto
Sent: Tuesday, August 11, 2009 2:55 PM
To: Jessica Cadwell
Subject: RE: Jane Doe
Yes — we are still trying to get the details though
From: Jessica Cadwell [mailto:
Sent: Tuesday, August 11, 2009 2:27 PM
To: Jacquie Johnson
Subject: RE: Jane Doe
Does this mean you have service on Maxwell
frJaca eY, Yccia'
Certified Paralegal
Florida Registered Paralegal
BURMAN CRITTON LUTTIER & COLEMAN, LLP
515 N. Flagler Drive
Suite #400
West Palm Beach, FL 33401
HOUSE OVERSIGHT 033503
From: Jacquie Johnson [mailto
Sent: Tuesday, August 11, 2009 2:30 PM
To: Jessica Cadwell
Subject: RE: Jane Doe
From: Jessica Cadwell [mailto:
Sent: Tuesday, August 11, 2009 11:28 AM
To: Jacquie Johnson
Subject: RE: Jane Doe
Do you have service on Maxwell or still trying to subpoena her??
frJae..a &dazeEE e?, cia'
Certified Paralegal
Florida Registered Paralegal
BURMAN CRITTON LUTTIER & COLEMAN, LLP
515 N. Flagler Drive
Suite #400
West Palm Beach, FL 33401
From: Jacquie Johnson [mailto
Sent: Tuesday, August 11, 2009 11:28 AM
To: Jessica Cadwell
Subject: RE: Jane Doe
Please notice the deposition of Ms. Maxwell has been rescheduled from 8/17 to 9/23. A re-Notice of Taking Deposition
will follow. Mr. Trump's deposition is scheduled for August 18, 2009.
From: Jessica Cadwell [mailto
Sent: Monday, August 10, 2009 3:31 PM
To: Jacquie Johnson
Subject: RE: Jane Doe
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No not likely. They just filed an emergency protective order
feJjka &dazeEE e?, cia'
Certified Paralegal
Florida Registered Paralegal
BURMAN CRITTON LUTTIER & COLEMAN, LLP
515 N. Flagler Drive
Suite #400
West Palm Beach, FL 33401
From: Jacquie Johnson [mailto
Sent: Monday, August 10, 2009 3:18 PM
To: Jessica Cadwell
Subject: RE: Jane Doe
Jessica — is the depo of going forward on Friday
From: Jessica Cadwell [mailto_____________
Sent: Monday, August 10, 2009 12:10 PM
To: Jacquie Johnson
Subject: RE: Jane Doe
I didnt forget about this...
Still working on it.
feJjka e?, cia'
Certified Paralegal
Florida Registered Paralegal
BURMAN CRITTON LUTTIER & COLEMAN, LLP
515 N. Flagler Drive
Suite #400
West Palm Beach, FL 33401
From: Jacquie Johnson [mailto______________
Sent: Thursday, August 06, 2009 10:47 AM
To: Jessica Cadwell
Subject: RE: Jane Doe
Jessica — I need a date for the deposition of Mr. Epstein. Can you provide me with one please?
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From: Jessica Cadwell [mailto
Sent: Thursday, August 06, 2009 10:20 AM
To: Jacquie Johnson
Subject: RE: Jane Doe
Great thank you. Do you have your Stays signed yet?
frJaca &dazeEE e9), Yccia'
Certified Paralegal
Florida Registered Paralegal
BURMAN CRITTON LUTTIER & COLEMAN, LLP
515 N. Flagler Drive
Suite #400
West Palm Beach, FL 33401
From: Jacquie Johnson [mailto
Sent: Thursday, August 06, 2009 9:59 AM
To: Jessica Cadwell; Bradley J. Edwards
Cc: Robert D. Critton Jr.
Subject: RE: Jane Doe
Brad is out of the office until this afternoon — I will ask him then.
From: Jessica Cadwell [mailto:________________________________
Sent: Thursday, August 06, 2009 9:51 AM
To: Bradley J. Edwards
Cc: Jacquie Johnson; Robert D. Critton Jr.
Subject: Jane Doe
Brad —
In your answers to ROGS, you list Milton Center for girls as facility that Jane Doe attended. Milton Center is a
Department of Juvenile Justice facility; therefore I will need to get her records from DJJ. DJJ will not release the records
without a signed release by Jane Doe. I have attached a general HIPPA release for your review. Would you please
have Jane Doe sign it? DJJ does not have a standard form.
Also, will you agree to one more week on Responses to Net Wirth ROGS??
Please let me know.
Jess —
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feJath &dwelt, e?, cia'
Certified Paralegal
Florida Registered Paralegal
BURMAN CRITTON LUTTIER & COLEMAN, LLP
515 N. Flagler Drive
Suite #400
West Palm Beach, FL 33401
***********************************************************
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation@gmail.com, and
destroy this communication and all copies thereof,
including all attachments.
HOUSE OVERSIGHT 033507

Topics

attorney coordination case management deposition scheduling discovery process legal correspondence victim advocacy

People Mentioned

Jeffrey Epstein Financier

Jessica Cadwell Attorney

Ghislaine Maxwell Socialite

Donald Trump Real Estate Mogul