Good-faith certification before defendants' motion over Epstein deposition, Sept. 2003

EFTA00187420¶

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA¶

NELSON SHANKS¶

Plaintiff,¶

CIVIL ACTION¶

LESLIE and ABIGAIL WEXNER, et al.¶

Defendants.¶

NO. 02-7671¶

CERTIFICATION OF GOOD FAITH EFFORTS TO RESOLVE DISCOVERY DISPUTES BEFORE FILING MOTION¶

J. Fox, Esquire, hereby certifies that he is counsel for Defendants and that prior to filing Defendants’ Motion for a Protective Order to reschedule and relocate the depositions of Jeffrey Epstein, Ghislaine Maxwell, and Abigail and Leslie Wexner, he engaged in good-faith efforts with Plaintiff’s counsel, Jeffrey Hofferman, to resolve this dispute. He wrote Mr. Hofferman a letter requesting rescheduling. Mr. Hofferman did not bother to respond to the letter.¶

J. Fox¶

Counsel for Defendants,¶

Dated: September 5, 2003¶

PHLIT\454486\1¶