Epstein Secrets

th.net Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By: c-=-:::-:::-,:::---c-:i==-::-:--:--:-::----=-: ROBERT D. RITTON, JR., ESQ. Florida Bar o. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive

e Doe II v. Epstein, and Kellen, Case No. 502008CA020614 MB AF, 15th Judicial Circuit Court, In and For Palm Beach County, State of Florida. Again, the Circuit Court Judge determined that the information sought is relevant to the issue of damages and, thus, discoverable. WHEREFORE, Defendant requests that this C

le, Suite 400 Boca Raton, Florida 33486 Telephone: (561) 955-7629 Facsimile: (561) 338-7099 By: Isl Stephen A. Mendelsohn STEPHEN A. MENDELSOHN Florida Bar No. 849324 [email protected] [email protected] [email protected] By: Isl Michael J G,ygiel MICHAEL J GRYGIEL (Admitted Pro Hae Vice) 54 S

County, Florida, in her official capacity (“Court Clerk”), alleges as follows: JURISDICTION L This is an action within the exclusive,jurisdiction of the Circuit Court pursuant to Fla. Stat. Sections 26.012(2)(a) and 86.011 et seq. PARTIES 2. The Palm Beach Post is a daily community newspaper published by Plaintiff

le, Suite 400 Boca Raton, Florida 33486 Telephone: (561) 955-7629 Facsimile: (561) 338-7099 By: /s/ Stephen A. Mendelsohn STEPHEN A. MENDELSOHN Florida Bar No. 849324 [email protected] [email protected] [email protected] By: /s/ Michael J Grygiel MICHAEL J GRYGIEL (Pro Hac Vice applicat

unty, Florida, in his official capacity (“Court Clerk”), alleges as follows: JURISDICTION 1. This is an action within the exclusive jurisdiction of the Circuit Court pursuant to Fla. Stat. Sections 26.012(2)(a) and 86.011 et seq. PARTIES 2. The Palm Beach Post is a daily community newspaper published by Plaintif

P MIA 000017 EFTA00209063 • • • JAY P. I.EFKOWITZ, ESQ. DFCEMBER 6,2007 PAGE 2 OF 4 any past or future delay. Mr. Epstein currently has four Florida Bar members on his defense learn, so attorney scheduling is not an adequate basis for delay. Three weeks ago I also asked you to provide our Office wit

utes over liability in public adversarial litigations. Initially, we proposed that Mr. Epstein create' trust whereby' trustee would be appointed by the Circuit Court to disperse the funds to the identified individuals based on' good faith showing of injury. In response, Ms. proposed the appointment of I guardia

ers 12 at ic. 12 perhaps at a different tine and even perhaps in a 13 MS. ROCKEHBACH: He was the ethics director 13 different forum. 14 for the Florida Bar for almost a decade, authoring 14 Really what has to be atterpted to be divined IS thousand➢ of opinions on legal ethics for lawyer➢ is today i

at I envisioned, your 2 results using now Chief Judge Gerber's, then Judge ) Honor. And I think Rothstein, Epstein all have to 3 Comber here in the Circuit Court, hi➢ voir dire 4 be part of that dialogue. a colloquy on hardship. It's excellent. And it is 5 MR. SCAROLA: I don't have a problem either 5 o

ers 12 at ic. 12 perhaps at a different tine and even perhaps in a 13 MS. ROCKEHBACH: He was the ethics director 13 different forum. 14 for the Florida Bar for almost a decade, authoring 14 Really what has to be atterpted to be divined IS thousand➢ of opinions on legal ethics for lawyer➢ is today i

at I envisioned, your 2 results using now Chief Judge Gerber's, then Judge ) Honor. And I think Rothstein, Epstein all have to 3 Comber here in the Circuit Court, hi➢ voir dire 4 be part of that dialogue. a colloquy on hardship. It's excellent. And it is 5 MR. SCAROLA: I don't have a problem either 5 o

3 FAX 305 630 8440 EXECUTIVE OFFICE JAY P. LEEKOWITZ, ESQ. DECEMBER 6, 2007 PACE 2 OF 4 any past or figure delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago I also asked you to provide our Office with

es over liability in public adversarial litigations. Initially, we proposed that Mr. Epstein create a trust whereby a trustee would be appointed by the Circuit Court to disperse the funds to the identified individuals based on a good faith showing of injury. In response, Ms. Villafana proposed the appointment of

3 FAX 305 630 8440 EXECUTIVE OFFICE JAY P. LEEKOWITZ, ESQ. DECEMBER 6, 2007 PACE 2 OF 4 any past or figure delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago I also asked you to provide our Office with

es over liability in public adversarial litigations. Initially, we proposed that Mr. Epstein create a trust whereby a trustee would be appointed by the Circuit Court to disperses to the identified individuals based on a good faith showing of injury. In response, t proposed the appointment of a guardian ad lite

(d) prohibits a lawyer from engaging in conduct in connection with the practice of law that is prejudicial to the administration of justice. In Florida Bar v. Frederick, 756 So. 2d 79, 87 (Fla. 2000), the court noted that FRPC 4-8.4(d) is not limited to conduct that occurs in a judicial proceeding, but

urity ‘camp-style’ facility” co-located with the Palm Beach County Sheriff’s Office. Both were administered by the Sheriff’s Office. 173 Plea in the Circuit Court, signed June 30, 2008, and filed in court. Villafaña complained to Goldberger when she learned later about the change from “imprisoned” to “jail se