Epstein Secrets

. I don't understand it. Explain it to me. MR. PIKE: To the extent you can answer that question without disclosing my conversations with you or Mr. Critton's conversations with you, as well as my work product, you can answer the question. THE WITNESS: I believe that as part of the scheme to defraud inv

erence was drawn, or not drawn, on a case-by-case basis under the microscope of the circumstances of that particular civil litigation." Id. (citing Graystone Nash, 25 F.3d at 192). The inference may not be drawn "unless there is a substantial need for the information and there is not another less burdensome w

02/2009 Page 16 of 16 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger Es . Robert D. Critton, Esq. s/ Adam D. Horowitz -16- EFTA00728216 Case 9:08-cv-80119-KAM Document 57-2 Entered on FLSD Docket 03/02/2009 Page 1 of 11 UNITED STATES

nst parties to civil actions when they refuse to testify in response to probative evidence offered against them"); Securities and Exhange Comm'n v. Graystone Nash, Inc., 25 F.3d 187, 190 (3d Cir. 1994) ("[t]he [defendant's] dilemma of choosing between complete silence and presenting a defense [in a civil case

2/2009 Page 16 of 16 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldber er, Es . Robert D. Critton, Esq. s/ Adam D. Horowitz -16- EFTA00222517

nst parties to civil actions when they refuse to testify in response to probative evidence offered against them"); Securities and Exhange Comm'n v. Graystone Nash, Inc., 25 F.3d 187, 190 (3d Cir. 1994) ("[t]he [defendant's] dilemma of choosing between complete silence and presenting a defense [in a civil case