Epstein Secrets

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

thers third-party privacy rights in that certain names may be mentioned in correspondence, including those on the "list." As noted in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): In 5tanley, 394 U.S., at 564, 89 S.Ct, at 1247, the Court stated:`(A)lso fundamental is

E 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] s/ Stuart S. Mermelstein - 11 - Case 9:08-cv-80119-KAM Document 81 Ent

in the exception of §39.204. D. Third Party Privacy Rights Are Not a Basis to Deny Discovery The right to privacy discussed in Eisenstadt v. Baird, 405 U.S. 438, 454 (1972), has nothing to do with the discovery issues in this case. Eisenstadt concerns the distribution of a contraceptive devic

es incurred and for any other relief to which he is entitled under the law. Jury Trial Plaintiff demands Jury Trial on all issues so triable. By: ROBERT D. CRITTON, JR., ESQ. MICHAEL J. PIKE, ESQ. BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 (Counsel for Jeffr

ist, Dr. Leonard Bard in Massachusetts; when the alleged police report reflected that EPSTEIN had only seen a chiropractor in Palm Beach named Dr. Baird. Obviously, no records existed for this alleged sex therapist, Dr. Bard, and the alleged subpoena for records was just another mechanism to "pump"

right by a jury. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by facsimile and United States mail to: Robert D. Critton, Esquire and Michael J. Pike, Esquire, Burman, Critton, et al., Attorneys for Defendant, 515 North Flagler Drive, Suite 400, West Palm Beach, Flori

lection to affirm. Hendricks v. Stark, 99 Fla. 277, 285, 126 So. 293, 296-97 (Fla. 1930) (internal quotation omitted); see, e.g., United States v. Baird, 218 F.3d 221, 230-31 (3d Cir. 2000) (recognizing that "quIntil the party who has the power of avoidance elects to exercise it, the contract remains

right by a jury. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by facsimile and United States mail to: Robert D. Critton, Esquire and Michael J. Pike, Esquire, Burman, Critton, et al., Attorneys for Defendant, 515 North Flagler Drive, Suite 400, West Palm Beach, Flori

lection to affirm. Hendricks v. Stark, 99 Fla. 277, 285, 126 So. 293, 296-97 (Fla. 1930) (internal quotation omitted); see, e.g., United States v. Baird, 218 F.3d 221, 230-31 (3d Cir. 2000) (recognizing that "quIntil the party who has the power of avoidance elects to exercise it, the contract remains

right by a jury. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by facsimile and United States mail to: Robert D. Critton, Esquire and Michael J. Pike, Esquire, Burman, Critton, et al., Attorneys for Defendant, 515 North Flagler Drive, Suite 400, West Palm Beach, Flori

lection to affirm. Hendricks v. Stark, 99 Fla. 277, 285, 126 So. 293, 296-97 (Fla. 1930) (internal quotation omitted); see, e.g., United States v. Baird, 218 F.3d 221, 230-31 (3d Cir. 2000) (recognizing that "'[u]ntil the party who has the power of avoidance elects to exercise it, the contract remain

right by a jury. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by facsimile and United States mail to: Robert D. Critton, Esquire and Michael J. Pike, Esquire, Burman, Critton, et al., Attorneys for Defendant, 515 North Flagler Drive, Suite 400, West Palm Beach, Flori

lection to affirm. Hendricks v. Stark, 99 Fla. 277, 285, 126 So. 293, 296-97 (Fla. 1930) (internal quotation omitted); see, e.g., United States v. Baird, 218 F.3d 221, 230-31 (3d Cir. 2000) (recognizing that "lujntil the party who has the power of avoidance elects to exercise it, the contract remains