Epstein Secrets

o be interpreted in favor of the defendants subjected to them. See United States v. Gradwell, 243 U.S. 476, 485, 37 S.Ct. 407, 61 L.Ed. 857 (1917); McBoyle v. United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); United States v. Bass, 404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (1

ntiff B: West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 [email protected] Counsel for Defendant Sarah Kellen .=__,;;=-------- ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLE

taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the applicable Statutes of Rules of Court. Robert D. Critton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing document is being served this day on all

o be interpreted in favor of the defendants subjected to them. See United States I . Gradwell, 243 U.S. 476, 485, 37 5.O. 407, 61 L.Ed. 857 (1917); McBoyle . United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); United States'. Bass, 404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (197

iew Mr. Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a non- adversarial resolution of all outstanding fee issues. Mr. Critton also transmitted to Mr. Josefsberg an Agreement for Special Master to Determine Amount of Attorneys' Fees and Costs ("Special Master Agreement"), s

, Defendant requests that this Court dismiss the entire action against him, and further grant his motion for more definite statement and to strike. Robert D. Critton, Esq. Attorney for Defendant Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of

, 117 S.Ct. 1219, 137 L.Ed.2d 432 (1997) (quoting McBoyle v. United States. 283 U.S. 25, 27, 51 S.Ct. 340,

Epstein Respectfully sub By:---;--.,,--.,...--- ROBERT D CRITTON, JR., ESQ. Florida Bar o. 224162 rcrit@bclclaw.

o be interpreted in favor of the defendants subjected to them. See United States v. Gradwell, 243 U.S. 476, 485, 37 S.Ct. 4O7, 61 L.Ed. 857 (1917); McBoyle v. United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); United States v. Bass, 404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (1

, Defendant requests that this Court dismiss the entire action against him, and further grant his motion for more definite statement and to strike. Robert D. Critton, Esq. Attorney for Defendant Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of

o be interpreted in favor of the defendants subjected to them. See United States v. Gradwell, 243 U.S. 476, 485, 37 S.Ct. 4O7, 61 L.Ed. 857 (1917); McBoyle v. United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); United States v. Bass, 404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (1

, Defendant requests that this Court dismiss the entire action against him, and further grant his motion for more definite statement and to strike. Robert D. Critton, Esq. Attorney for Defendant Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of

ng fair, so far as possible the line should be clear.' " United States v. Lanier, 520 U.S. 259, 265, 117 S.Ct. 1219, 137 L.Ed.2d 432 (1997) (quoting McBoyle v. United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931)) (omission in original). The "three related manifestations of the fair warning

. Accordingly, Plaintiff's cause of action thereunder is barred. WHEREFORE Defendant requests that this Court deny the relief sought by Plaintiff. Robert D. Critton, Jr. Attorney for Defendant Epstein EFTA00221254 Case 9:08-cv-80232-KAM Document 115-2 Entered on FLSD Docket 06/09/2009 Page 10 of 10 Jane D

o be interpreted in I favor of the defendants subjected to them. See United States Gradwell, 243 U.S. 476, 485, 37 S.Ct. 407, 61 L.Ed. 857 (1917); McBoyle . United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); United States'. Bass, 404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (197

SES ONLY) 20* NOTE: IN LAND CONDEMNATION OASES. fay. 24, THE 7 LAND 'IWO/val. SYEVEm R4 LARluODE AC I Attorneys Or Keen) CLERK U.S. DIST. CT. Robert D. Critton, Esq., Burman, (..sitioltaataCaitIL.L...p, • 303 Banyan Blvd., Suite 400, West Palm Beach, FL 33401 WI Check County Whine Mien &OM CI MIAMI. OAHE