Epstein Secrets

ra-Johnson Page 29 Respectfully submitted, By: Isl Robert D. Critton, Jr. ROBERT D. CRITTON, JR., ESQ. Florida Bar N

e legal consequences of their actions. FNl8. See General Motors Corp. v. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105, 11

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

s attorney. 12. The attorney-client privilege also extends to subordinates of a party's attorney. -- - - - - - ··- --·· -· -- . -- See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege

t Jeffrey Epstein EFTA00722741 Case 9:08-cv-80119-KAM Document 79 Entered on FLSD Docket 04/17/2009 Page 7 of 7 Page 7 Respectfully sub By: ROBERT D. CRITTON, JR., ESQ. Milit 4162 MICHAEL J. PIKE, ESQ. ER & COLEMAN Phone Fax (Co-Couruel for Defendant Jeffrey Epstein) EFTA00722742 37 93dge 9:08-0130

settled that a Defendant may take the deposition of a ma and/or a witty-cc before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and lave v. General Motors Corp., 43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2-7 commenced separate civil actions upon the filing of same against Jeffrey Epstein. Therefore, Def

ut federal grand juries and would also cause Epstein irreparable harm. "If the proverbial horse is out of the barn, you can't get him back in." Critton argued. Attorneys for women now suing Epstein. to- gether with an attorney for Epstein Pleaded guilty to solicitation and procunng teenagers

ere 34 percent lower than a year ago. "Stimulating sales is the only way to get the auto industry back on its led," said Rep. Donald Manzullo, General Motors Corp. and Chrysler LLC have received billions of dol- lars in government aid and the entire auto indus- try has watched car sales plummet during the pa