Epstein Secrets

xpert discovery must be completed on June 29, 2009 for C.M.A. 6. As to C.M.A., Jane Doe and Jane Does 2-7, each has objected to relevant discovery. C.M.A. has even refused to produce certain information that she agreed to produce in discovery. The foregoing delay tactics has prevented Epstein from co

nd d. for such other and further relief as this co deems just and proper. By: ROBERT TTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 11 EFTA00221765 Case 9:08-cv-80119-KAM Document 104 Entered on FLSD Docket 05/19/2009 Page 12 of 13 Co-Counsel for

is Court subsequently denied on December 12, 2008 (DE 28). The case was transferred from Judge Zloch to this division on September 3, 2008 (DE 21). C.M.A. filed her First Amended Complaint on February 10, 2009. (C.M.A. DE 39-40). Epstein's Motion to Dismiss same was filed on March 12, 2009. (C.M.A. DE

trial date; and d. for such other and further relief as this couryldeems just and proper. By: ROBERT D CRITTON, JR., ESQ. Florida Bar o. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of th

A/JOHNSON, in Defendant's Motion to Dismiss directed to Plaintiff C.M.A.'s Amended Complaint, Plaintiff C.M.A.'s Response, and Defendant's reply to C.M.A.'s response (which has yet to be filed). In this action, Plaintiffs Complaint attempts to allege a cause of action pursuant to 18 U.S.C. §2255 - Civ

te act relied upon. WHEREFORE, Defendant respectfully requests that this Court dismiss Plaintiffs entire action. By: ROBERT D RITTON, JR., ESQ. MICHAEL J. PIKE, ESQ. EFTA00222838 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 27 of 29 Jane Doe II v. Epstein, et al. Page 27

r the 9 agreement is supposed to be admitted. Now, as to the amount of 10 damages, there are legal issues that will be before you and 11 under the C.M.A. cases that are getting before you, as to 12 whether it is 50 or 150. That has nothing to do with the NPA. 13 There are legal issues that are befor

rt, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 Fax. 561 828 0983 Counsel for Defendant Robert D. Critton, Esq. Michael J. Pike, Esq. Burman, Critton, Luttier & Coleman, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach, Florida 33401 Fax. 561 515 3148 Co-Counsel for J

sponse in Opposition to Motion, filed by Jeffrey Epstein, 114 Motion for Protective Order filed by C.M.A., 121 Motion for Protective Order, filed by C.M.A., 137 Motion to Strike filed by Jeffrey Epstein. Signed by Magistrate Judge Linnea R. Johnson on 7/16/2009. (ail) (Entered: 07/17/2009) NOTICE of Co

a Elkins 8 Boehringer 224 Datura Avenue Suite 900 West Palm Beach , FL 33401 USA 561-832-8033 Fax: 832-7137 Email: [email protected] Michael James Pike [COR LD NTC] Burman Critton Luttier 8 Coleman 303 Banyan Boulevard Suite 400 West Palm Beach , FL 33401-2918 USA 561-842-2820 Fax: 561-253-01