Epstein Secrets

n Avenue South Suite 1400 West Palm Beach, FL 33401-5012 o- ounse or e endant Jeffrey Epstein Respectfully sub By: ROBERT D. RITTON, JR., ESQ. Florida Bar o. 224162 rcritabcicl w.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpikeabcIclaw.com BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive

by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it will

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 nsor & Associates Reponing aid Tram ripurm, Inc 1 2 Page 48 Florida Bar? A. I did not select him. 3 Q. Who did? 4 A. My father. 5 Q. Did you ever meet Mr. Herman? 6 A. Once. 7 Q. Don't -- don't tell me wh

e 6(e) remains non-public, thus effectuating the privacy concerns addressed by the United States Supreme Court in Douglas and other cases. See e.g. Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 228-30 (1979). Under Rule 6(e), only a federal court can, absent findings, order the unsealing of federal

& ASSOCIATES, LLC Attorneys for Plaintiff 2028 Harrison Street - Suite 202 Hollywood, Florida 33020 Telephone: Facsimile: Jay Howell, Esquire Florida Bar JAY HOWEEL SSOCIATES, P.A. Co-Counsel for Plaintiff 644 Cesery Boulevard - Suite 250 Jacksonville, Florida 32211 Telephone: Facsimile: By: Bra

The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available