Epstein Secrets

of $506,847.78 for 5 years of sexual harassment and sexual touching was reasonable). Unfortunately, the parties were unable to reach a agreement. Myers clearly demonstrates that Epstein's offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe

offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe as compared to the allegations in Myers. Moreover, allowing such discovery at this juncture goes against the grain and the law in that Plaintiff has not made a reasonable showing establish

l of record identified on the following Service List in the manner specified by CM/ECF on this 141 day of April, 2010. Respectfully submitted, Br ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLE

kes it clear that there is a compelling need for any net worth discovery not protected by the Fifth Amendment privilege. 5 Defendant relies upon Myers v. Central Florida Investment, Inc., 592 F.3d 1201 (11th Cir. 2010) for its “stipulation” argument. In Myers, however, the district court heard tes

Myers, however, the district court heard testimony regarding each of the defendant’s net worth. There was no unilateral statement of net worth in Myers as Defendant wishes to create in the instant case. To the extent that Defendant relies upon the Court’s holding in Myers regarding the reasonablen

LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Bradley James Edwards [email protected] Isidro Manuel Garcia [email protected] Jack Patrick

Amendment privilege. 5 Defendant relies upon Myers v. Central Florida Investment, Inc., 592 F.3d 120

here was no unilateral statement of net worth in Myers as Defendant wishes to create in the instant case

Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Bradley James Ed

ar-old Jason Roden of Loxahatchee. "He was a wonderful boy, and he did a lot for 111 ;29.9.3 • Absolut Vodka I Three Olives • -- '24.99 Myers Platinum Rum $1659 $ Chivas — Regal '49.99 The I $ , Macallan J‘. • 39.99 g Early lime • Canadian Mist .. 46.99 Wild Turkey '29

ut federal grand juries and would also cause Epstein irreparable harm. "If the proverbial horse is out of the barn, you can't get him back in." Critton argued. Attorneys for women now suing Epstein. to- gether with an attorney for Epstein Pleaded guilty to solicitation and procunng teenagers