Epstein Secrets

EDWARDS, ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 401 East Las Olas Boulevard Suite 1660 Fort Lauderdale, Florida 33394 On behalf of the Defendant: ROBERT D. CRITTON, JR., ESQUIRE BURMAN, CRITTON & LUTTIER 303 Banyan Boulevard, Suite 400 West Palm Beach, Florida 33401 On behalf of the Witness: BRUCE REINHART,

Correct. They're pilot logs, not night logs. There are other records we indicated are corporate records, and with those you have to deal with Mr. Critton. MR. CRITTON: However, with the proviso, too, Case 9:08-cv-80119-KAM Document 402 Entered on FLSD Docket 11/09/2009 Page 18 of 26 I I I I

d beyond September of 2005. Therefore whatever information Mr. Zinoview may have, postdates that time. 5. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi

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

r conversations with hei· supervising partner as the questions invaded the attorney-client privilege). 14. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi

ed on the following Service List in the manner specified by CM/ECF on this 29th day of March 2009. Respectfully submitted, By: s/Michael J. Pike ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLE

opriate and irrelevant and not reasonably calculated to lead to the discovery of admissible evidence." 24. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order,2 "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson