Epstein Secrets

Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 14 Case 9:08-cv-80119-KAM Document 2

e Radiator, Inc. v. Radiator Express Warehouse, 2008 WL 842989 (M.D. Fla. 2007)(protecting investigative materials as work-product); and Hickman v. Taylor, 329 U.S. 495, 508, 67 S.Ct. 385, 91 L.Ed. 451 (1947)(noting, among other things and subject to exception, that work-product includes information w

f Doe Isidro M. Garcia, Esq. Garcia Law Finn, P.A. 224 Datum Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F 0840469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 1.4 EFTA00729257 Counsel for Plaintiff

e Radiator. Inc. v. Radiator Express Warehouse, 2008 WL 842989 (M.D. Fla. 2007)(protecting investigative materials as work-product); and Hickman v, Taylor, 329 U.S. 495, 508, 67 S.Ct. 385, 91 L.Ed. 451 (1947)(noting, among other things and subject to exception, that work-product includes information w

the 12th claim by a young woman who also says she was lured to his Palm Beach mansion as a teen and sexually abused. Prominent Miami at- torney Robert Josefsberg filed the most recent federal lawsuit last week, on behalf of the Jane Doe 101 who allegedly visited Epstein a few times while 17 years old and

each County for two weeks filming A See G-STAR, 5B P. > WANT MORE? See a gallery of photos from the movie set. pbcals*.com Appointed or not, Rep. Taylor to seek Greene's seat in 2010 By GEORGE BENNETT Palm Beath Post Staff Hinter WEST MLNI BEACH — State Rep. Priscilla Taylor will run for a Palm

strict Judge Edward B. Davis, an esteemed jurist — was assigned the task of selecting and consulting with the Epstein-paid attorney-representative, Robert C. Josefsberg, Esq., to pursue claims on behalf of the victims against Mr. Epstein under 18 U.S.C. §2255. See Letter from FAUSA Jeffrey Sloman to Hon. Edward B.

claim and issue preclusion to nonparties thus runs up against the `deep-rooted historic tradition that everyone should have his own day in court." Taylor v. Sturgell, 553 U.S. 880, 892-93 (2008) (citation omitted). Contrary to Petitioners' argument that "all of the Court's previous holdings are now la

efsberg et al City National Bank Building 25 W Flagler Street Suite 800 Miami FL 33130-1780 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Robert C. Josefsberg Podhurst Orseck Josefsberg et al City National Bank Building 25 W Flagler Street Suite 800 Miami FL 33130-1780 Fax: Email: LEAD ATTORNEY ATTOR

to effectuate their purpose), citing., Hickman v. Taylor 329 U.S. 495, 501, 507 (1947). 15. Next, the r

gency and sought no expedited relief, Mr. Epstein, pursuant to his obligation under the Non-Prosecution Agreement, paid an attorney representative, Robert Josefsberg, substantial legal fees to represent many of the witnesses against him and settled many civil cases brought by the attorney representative. Mr. Eps

)? the better reasoned conclusion is that Rule 612 does apply at depositions. 1. The Work Product Doctrine In the now famous case of Hickman 11. Taylor, 329 U.S. 495, 67 S.Ct. 385, 1 L.Ed. 451 (1947), the Supreme Court re- cognized the work product doctrine. The doctrine creates a "protected zone"