Epstein Secrets

ast Las Olas Boulevard 10 Suite 1650 Fort Lauderdale FL 33394 11 12 13 On behalf of the Defendant: 14 BURMAN, CRITTON, LUTTIER & COLEMAN BY: ROBERT D. CRITTON, JR., ESQ. 15 and MICHAEL J. PIKE, ESQ., 515 North Flagler Drive 16 Suite 400 West Palm Beach, FL 33401 17 18 19 20 21 22 23 24 25 EF

ay I explain that? 10 MR. CRITTON: No. 11 THE COURT: Hold on. 12 MR. BERGER: We have three clients. One 13 is in federal court, Jane Doe. Mr. Critton 14 wants to take Jane Doe's deposition in these two 15 cases, and III., so she's in front of you 16 as a nonparty on a motion for protective o

76, and that was a decision of the Fifth District Court of Appeal, and I will quote headnote 3, "had the Petitioners brought their lawsuit against Ruzzo and the Board Room only under Section 769.09, evidence of Petitioner's past prostitution 8 including with the Board Room and their earnings 9 r

ourt they sit, is going to be entitled to a fair shake and a fair trial and entitled to the EFTA00776411 47 1 2 3 4 5 6 7 the Ballast vs. Ruzzo case. For the record, the citation is 703 So.2d. 1076, and that was a decision of the Fifth District Court of Appeal, and I will quote headnote 3,

tralian Avenue South Suite 1400 West Palm Beach Florida 33401 Fax. Counsel for Defendant Robert D. Critton, Esq. Michael J. Pike, Esq. Burman, Critton, Luttier & Coleman, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach Florida 33401 Fax. Co-Counsel for Jeffrey Epstein 25 LeVykt:11:, in

ruce E. Reinhart, Esq. Bruce E. Reinhart, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach Florida 33401 Fax. Counsel for Defendant Robert D. Critton, Esq. Michael J. Pike, Esq. Burman, Critton, Luttier & Coleman, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach Florida 33401 Fax. Co-Coun

, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Bala: v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution,"

inst such claims by the mo direct and traditional of metlmd,, Le., proof ilifil rnch drum, = Smpfy oot true. Id. l ----'-'""----4------- R ob e rt D. Critton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the C

requested information is not relevant? 7. Next, despite Plaintiffs' strained interpretation and application of the discovery requests in Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), that case is instrumental in that, once again, we are at the "discovery

5012 561-659-8300 Fax: 561-835-8691 [email protected] Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By: __ -1-:....::.. ____ _ ROBERT D CRITTON, JR., ESQ. Florida Ba No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEM

anation for why victim exhibited behavioral manifestations of sexually abused child.). In further support of Defendant's motion, a copy of Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as Exhibit A as it is on point to the discovery iss

, Esq. McIntosh, Sawran, Peltz & Cartaya P.A. Counsel for Defendant Haley Robson Bruce E. Reinhart, Esq. Bruce E. Reinhart, P.A. n an •ra e en Robert D. Critton, Esq. Michael J. Pike, Esq. Burman, Critton, Luther & Coleman LL' o- ounse or cirey Epstein 25 Lewis Teinrv. 3059 Gum) Avow,. Sum 140. Cot owl

e, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Baku v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution,"