UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 EPSTEIN'S MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF STORY COWLES AND INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 26(c), Federal Rules of Civil Procedure, moves for a protective order to prohibit the deposition of Story Cowles, and states: I. Plaintiff, Jane Doe (Case No. 08-80893), noticed the deposition of Story Cowles for May 12, 2010 (Notice and Subpoena attached as Exhibit A). 2. Mr. Cowles was hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on July 16, 2008 and has been employed by Mr. Goldberger since that time. Mr. Cowles was hired as Mr. Goldberger's law office assistant to be directly involved only with Mr. Epstein's case while he was serving his jail sentence at the Palm Beach County Stockade. Mr. Cowles was employed to be, among other things, a conduit for information between the attorneys (criminal EFTA00728104