Epstein Secrets

Document 60 Entered on FLSD Docket 04/17/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-NIARRA/JOHNSON C.M. A., Plaintiff, v. i EPSTEIN and Defendants, DEFENDANT's MOTION FOR EXTENSION OF TIME IN WHICH TO FILE A REPLY TO PLAINTIFF'S RESPONSE TO

Court deny the Motion, enter an order allowing for the relief requested herein and for such other relief ap5bis court deems just and proper. obert 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

ally provide a 'lead or clue' to evidence having a tendency to incriminate. 8. In Jane Doe No. 2 v. Epstein, Case No. 08-CIV-80119 MARRA/JOHNSON, the Court sustained Epstein's Fifth Amendment objections to several interrogatories asking Epstein to identify information potentially related to t

tein EFTA00723231 v. Epstein Case No. 502008CA037319XXXXMB AB Page 14 of 14 BURMAN, CRITTON, LUTTIER & COLEMAN, LLP (561) 515-31 ax By: R D. Critton, Jr. orida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) EFTA00723232 IN THE CIRCUIT COURT OF THE 1

plaintiffs from attempting to depose other paralegals, secretaries, legal assistants, investigators or even attorneys employed by Epstein? As Judge Johnson noted, "while the scope of discovery is broad, it is not without limits." See DE #377. Jane Doe is clearly attempting to exceed the limits of permi

Mr. Epstein to his attorneys and staff, would be protected by the attorney-client and work product privileges. See Exhibit B; see also Affidavit of 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

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-cv-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, CASE NO.: 08-CV-80380-MARRA/JOHNSON

en for the purpose of discovery, for use at trial, or for stet other purposes as are permitted under the applicable Statutes of Rules of Court. bit D. Critton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true and correct copy of the foregoing document is being serve

ttorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #21. United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON Dear Mr. Lee: I am writing to inquire about whether Mr. Epstein has violated his Non-Prosecution Agreement with the Government. As you know, the

, to allow him to deposit $2,000,000 in Trust with the Court pending the outcome of the Complaint which confirms his commitment. Cordially yo Rob D. Critton, Jr. RDC/JPL:ab Cc EFTA00183041 L EFTA00183042 . (USAFLS) From: Acosta, Alex (USAFLS) Sent: 811:55 AM To: . (USAFLS); Sloman, Jeff (USA

istrict of Florida 500 East Broward Boulevard, 7th Floor Ft. Lauderdale, FL 33394 Re: Jane Doe No. 81 Jeffrey Epstein Case No. 09-CV- 0802-Marra/Johnson Dear Ms. Villafana: ADF1QUI 1. BENAVEWIE PARALEGAL/INVESTIGATOR BARBARA M. McKENNA ASIILIE STOKEN-BARING BEITY STOKES PARALEGALS RITA H. BUDN

ding this motion or any other civil related pleadings or matter that may implicate the NPA. I look forward to your response. Cordially y rs, Robe, D. Critton, Jr. RDC/clz cc by pdf: Jack A. Goldberger, Esq. Martin G. Weinberg, Esq. Roy Black, Esq. Jay Lefkowitz, Esq. EFTA00194734 UNITED STATES DIS

ttorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2'. United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON Dear Mr I am writing to inquire about whether Mr. Epstein has violated his Non-Prosecution Agreement with the Government. As you know, the Govern

, to allow him to deposit $2,000,000 in Trust with the Court pending the outcome of the Complaint which confirms his commitment. Cordially yo Rob D. Critton, Jr. RDC/JPL:ab Cc AUSA - , AUSA — Jack Goldberger, Esq. Robert Josefsberg, Esq EFTA00233363 1 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JU