Epstein Secrets

ck Alan Goldberger Atterbury Goldberger & Weiss. P.A. Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By: ROBERT D. RITTON, JR., ESQ. Florida Bar o. 224162 rcritabcIclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpike(abciclaw.com EMAN EFTA00221702

ative explanation for why victim exhibited behavioral manifestations of sexually abused child.). In further support of Defendants motion, a copy of Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as Exhibit A as it is on point to the discovery iss

25 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 nsor & Associates Reportiny and lranscrirrix, inc Page 48 1 Florida Bar? 2 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 w

sake of the defendant, but because [the courts] will not lend their aid to such a plaintiff" (quoting Holman, 98 Eng. Rep. 1120)) (emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. 5th DCA 1997) (Harris, J., concurring) (remarking in the context of an action brought against an alleged prostitution

e 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 nsor & Associates ReparlillS and 1.71111Gliptill11. Inc. Page 48 1 Florida Bar? 2 A. I did not select him. 3 Q. Who did? 4 A. My father. 5 6 7 8 with him. Where did you meet him? 9 10 friend's house. 11 12 13

sake of the defendant, but because [the courts] will not lend their aid to such a plaintiff" (quoting Holman, 98 Eng. Rep. 1120)) (emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. 5th DCA 1997) (Harris, J., concurring) (remarking in the context of an action brought against an alleged prostitution

5 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 sor & Associates [tenoning and Inniscrivinn. Inc. Page 48 1 Florida Bar? 2 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

sake of the defendant, but because [the courts] will not lend their aid to such a plaintiff" (quoting Holman, 98 Eng. Rep. 1120)) (emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. 5th DCA 1997) (Harris, J., concurring) (remarking in the context of an action brought against an alleged prostitution