Epstein Secrets

y, Hafele also said that videos from depositions in the state cases can't be; released without a cOurt order. The ruling came; after Epstein attorney Robert Critton complained that a video of Epstein being asked whether he had,an "egg-shaped" penis became a youtube.com sensation. It first appeared on The Palm Bea

video of Epstein being asked whether he had,an "egg-shaped" penis became a youtube.com sensation. It first appeared on The Palm Beach Post Web site. Critton blamed attorney Spencer Kuvin for releasing it. Kuvin said it was public record. The civil suits began mounting after Epstein agreed to plead guilty

2:57:43 PM • “Woman Sues Billionaire Investor, Says They Had Sex When She Was 16” published on October 18, 2007, reporting on a lawsuit brought in New York State court against Epstein “by a young woman who says he had sex with her when she was 16 and had sought his help becoming a model.” • “Palm Beacher Plead

ay, Hafele also said that videos from depositions in the state cases can't be released without a court order. The ruling came after Epstein attorney Robert Critton complained that a video of Epstein being asked whether he had an "egg-shaped" penis became a youtube.com sensation. It first appeared on The Palm B

ideo of Epstein being asked whether he had an "egg-shaped" penis became a youtube.com sensation. It first appeared on The Palm Beach Post Web site. Critton blamed attorney Spencer Kuvin for releasing it. Kuvin said it was public record. The civil suits began mounting after Epstein agreed to plead guilty

his case.” • “Woman Sues Billionaire Investor, Says They Had Sex When She Was 16” published on October 18, 2007, reporting on a lawsuit brought in New York State court against Epstein “by a young woman who says he had sex with her when she was 16 and had sought his help becoming a model.” • “Palm Beacher P

ST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Isidro Manual Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell K

t” standard for production than would otherwise apply to discovery. Epstein’s Appeal at 15. The authority for this claim is said to be Trudeau v. New York State Consumer Protection Bd., 237 F.R.D. 325 (N.D.N.Y. 2006), which reviews some decisions from within the Second Circuit and Case 9:08-cv-80119-KAM D

60, Line 10 22 23 24= Letter to John Randolph,.Esq.: 25. Errata-Shects (to be forwarded upon completion) Page 4 1 APPEARING ON BEHALF OF DEFENDANT: 2 ROBERT D. CRITTON. ESQ. BURMAN. CRITTON,EUTT1ER & COLEMAN. LLP. 3 515'North‘Flagler Drive, Suite 400 VVest Palm Beach,- Florida 33401 .4 5 JACK GOLDBERGER,:ESQ. ATTENB

any attempt to flee. Indeed, his potential avenues of flight from justice are practically limitless. As the defendant acknowledged in his most recent New York State sex offender registration, he has six residences, including two in the U.S. Virgin Islands (including his own private island), and one each in Palm B

cia ISIDRO M. GARCIA CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN CRITTON LUTTIER & COLEMAN, this 12th day of June, 2009. BY:s/ Isidro M. Garcia ISIDRO M. GARCIA 2 EFTA0022

led in the Affidavit of Service of Joseph Sanchez, attached as Exhibit 1. 2. Mr. Sanchez effected service on Defendant in a manner authorized by New York State law, and Defendant has failed to timely answer the complaint or otherwise respond thereto. 3. Defendant is aware of this action and has in fact

Telecopier: e-mail: CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN CRITTON LUTTIER & COLEMAN, Counsel for Defendant EPSTEIN, 515 N. Drive, Suite 400, West Palm Beach, Florida 33

iciency of service. Conspicuously absent is any statement or inference that the defendant did not receive the papers served upon her or that, under New York State law, due diligence was not made. Schwarz I Margie, 2009 NY Slip Op 03890, 62 A.D.3d 780 (May 12, 2009); Leyiton Unger, 2008 NY Slip Op 09363, 56 A.D

8/2009 Page 15 of 15 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. Robert D. Critton, Esq. Bradley James Edwards Isidro Manuel Garcia Jack Patrick Hill Katherine Warthen Ezell Michael James Pike Paul G. Cassell Richard Horace W

legal precedents for the inclusion of psychiatric testimony in matters concerning wrongful death of a parent and loss of parental services, in both New York State and California. He has testified in over 275 cases including over 100 trials. A Federal Rule 26 list is available on request and on www.expertchild