Epstein Secrets

10/06/2008 46 Defendant's MOTION to Dismiss 42 Amended Complaint and for More Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Critton, Robert) (Entered: 10/06/2008) 10/24/2008 4/ Unopposed MOTION for Extension of Time to File Response as to 46 Defendant's MOTION to Dismiss 42 Am

Fax. 6 EFTA00175615 Case 9:08-cv-80( •KAM Document 40 Entered d LSD Docket Ofd '2008 Page 7 of 8 CASE NO.: 08-80119-CIV-MARRA/JOHNSON By: Robert D. Critton, Esq. Fla. Bar No. 224162 [email protected] Michael J. Pike, Esq. Attorneys for Defendant Jetty Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL

access creates a presumption in favor of openness of court records, which "must be balanced against any competing interest advanced." United States Noriega, 752 F. Supp. 1037, 1040 (S.D. Fla.1990). For example, courts may look to see whether the records sought are for illegitimate purposes. Ma 696 F.2d

tating and belief that the communications to Mr. Epstein from his attorneys and staff, work product privileges. See Exhibit B; see also Affidavit of Robert D. Critton, Jr. attached as Exhibit D. 4. Mr. Cowles did not know, nor did he have any knowledge of, Mr. Epstein prior to his employment with Mr. Goldberger. See

committing a crime or tort; and (4) the privilege has been (a) claimed and (b) not waived by the client. Id. at *2 (emphasis added), citing U.S. v. Noriega, 917 F.2d 1543, 1550 (11th Cir. 1990). 13. In Seeback, the court granted a protective order where a party sought to discover information from a pa

48 6 EFTA00222728 Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 7 of 8 CASE NO.: 08-80119-CIV-MARRA/JOHNSON By: Robert D. Critton, Esq. Fla. Bar No. 224162 [email protected] Michael J. Pike, Esq. Fla. Bar No. 617296 [email protected] Attorneys for Defendant Jeffrey Epst

ccess creates a presumption in favor of openness of court records, which "must be balanced against any competing interest advanced." United States" Noriega, 752 F. Supp. 1037, 1040 (S.D. Fla.1990). For example, courts may look to see whether the records sought are for illegitimate purposes. 696 F.2d at