Epstein Secrets

ED Michael Ross Tein Lewis Tein 3059 Grand Avenue Suite 340 Cocos Grove , FL 33133 Fax: 442- 4 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Robert Deweese Critton , Jr. Burman Critton Luttier & Coleman 515 N Flagler Drive Suite 400 West Palm Beach , FL 33401-2918 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE

Doe Epstein, et. al. CASE NO: 08-80804-Civ-MARIUUJOHNSON United States District Court, Southern District of Florida Robert Critton, Esq. Burman, Critton, Luttier & Coleman, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 Phone: Fax: Counsel for Jeffley Epstein Served via U.S. Mail,

-80804-C1V-MARRA/JOHNSON BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach. Florida 33401 Tel. Fax. By: Robert D. Critton, Esq. Fla. Bar No. 224162 [email protected] Michael J. Pike, Esq. Fla. Bar No. 617296 Attorneys for Defendant Jeff Ry Epstein CERTIFICATE OF

who is the target of the actor's conduct does not control the question of whether the tort [of LIED] occurred." Bartsch, 522 So. 2d at 1056 (citing Patton, 468 So. 2d at 1011) (emphasis added). Here, the plaintiff alleges, at most, that coordinated an openly illegal transaction with her (DE 1-3 at 103)

l from Ms. Eden re: interview notes; telephone conference with Ms. Eden re: same; exchange emails with Ms. Sheehan re: same. Review email from Mr. Critton re: tolling agreement; review email from Mr. Josefsberg re: same; review email from Mr. Josefsberg re: Defendant ands review email from Ms. Sheeha

eply email from Mr. Josefsberg to Ms. Ezell re: settlement Review email from Ms. Sheehan re: complaint and interview notes; review entail from Ms. Patton re: service of process. Review email from Ms. Ederi re: interview notes. Review emails from Ms. Sheehan re: tolling agreement ands tiails revie

ting; ~; review reply from Ms. en; review email from Ms. Ezell re: anonymity and deposition transcript. Review email from Mr. Josefsberg to Mr. Critton re: 9/25 settlement; review and send replies between team; telephone conference with Mr. Eden re: same; review email from Ms. Estrada . rc: depos

email from Ms. Ezell re: SA language; review reply from Ms. Eden; review email from Ms. Ederi re: settlement issues. Review email forward from Ms. Patton of email from Mr. Josefsberg forwarding email from Mr. Critton attaching 10/15/09 letter re: settlement negotiations; review same; review email fo

review emails from Ms. Ezell it: same; review email from Ms. Ezell re: conferring with opposing counsel; reply; review email from Ms. Ezell to Mr. Critton re: time for scheduling conference; review email from Ms. Ezell re: same; reply re: timing; review reply from Ms. Ezell; review email from Ms. Eze

6/22/09 send replies; review motion to file under seal; edit reply re: same; review email re: revisions by Mr. Josefsberg; review email from Ms. Patton re: and attaching reply to motion to preserve; revise same; conference with Ms. Eden re: and revising filings; review email from Ms. Rasco attachi

cription of Service Review email from Ms. Ederi to team attaching JIMINNIM telephone conferences with Ms. Ederi re: meeting with Defendant and Mr. Critton today with Ms. Eden and Mr. Josefsberg and re: other miscellaneous issues; review email from Ms. Ederi re: and attaching revisions to my notes of

review and prepare notes re: same; telephone conferences with Ms. Eden re: revision to same; review email from Ms. Ezell forwarding email from Ms. Patton re: anonymous telephone call; research re: same; review email from Ms. Ezell reeand ; review email tom Ms. Ezell attaching SM agreement and opin

General Description of Service Review email from Ms. Ederi re: telephone conference; review email from Ms. Ederi re: and attaching email from Mr. Critton re: meeting, SM agreement, and evaluator; review reply from Mr. Josefsberg; review emails from Ms. Ederi re: motion for no-contact order. Review

reply from Ms. Ezell; review email from Mr. Josefsberg re: end deposition duces tecum of Mr. Rodriguez; review email from Mr. Josefsberg to Ms. Patton and Mr. Doddo re: a s review email from Ms. Ezell re: accessing evidence; review reply from Mr. Josefsberg; reply to Ms. Ederi re: motion for no- c