Epstein Secrets

Have you over pied any allegations, Mr. Berger, that turned out to be untrue. down the lino? 1 4 S 147 Epstein? A It's patently [also that Jeffrey Epstein wan not Intel injured by anything that Brad Edwards did or if -- I don't deny that there wan a 0042l scheme that used the three cases we had as bait.

Boulevard, Suite 1001 $ 9:27 West Palm Beach, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevar

, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevard, Suite 301 0 9 West Palm Beach, FL 33401 B

th Florida. He had a case -- ho had cases against Mr. Epstein. Or he had clients -- I don't know if he actuall

appens -- and things that they do 2 Q So before you took on the representation of 2 afterwards -- that they are touched -- is information 3 ., E.N. and Jane Dee, your only experience with ) you would evaluate in evaluating their case, wouldn't 4 alleged sexual abuse were three -- 4 you? 5

Colbath Palm Beach County Courthouse Fifteenth Judicial Circuit 205 North Dixie Highway, Room 11F West Palm Beach, FL 33401 June 30, 2009 Re: Epstein v. State of Florida 15th Circuit Court Case No. 2008CF009381A Dear Judge Colbath: rELEPNowc (561 ) 659-5455 rAcsimax (Bet) ) 820-8752 Enclosed i

ency Requet: 19411 SDNY_GM_00331639 EFTA 00204365 EFTA02729351 • IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Respondent. CASE NO. PALM BEACH LT. CASE NO. 2008 CF 009381A EMERGENCY PETITION FOR WRIT OF CERTIORARI Pet

ED APPELLATE LAWYERS By Hand Delivery Honorable Jeffrey Colbath Palm Beach County Courthouse Fifteenth

between the United States Attorney's Office and Mr. Epstein were filed under seal in state court at the expr

this case"--and not by Petitioner, Jeffrey Epstein is referred to by proper name. Non-party interveners, E.W., B.B. and The Post are referred to as E.N., B.B. and The Post. All emphasis is supplied unless indicated otherwise. The following symbol is used: A — Petitioner's appendix. 0911212019 3241

f his clients is the purported victim. Accordingly, I will address facts related to C.W., T.M., and S.R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. 'Please note that the dates on the U.S. Attorney's Office letters to C.W. and T.

tates receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. (NPA, paragraph 13(emphasis added.) The first sentence of the above quote does no more than state an expectation b

8:4 15:19 11:19,24 1:17 2:10,11 moment 13:24 3:10 2:13 15:16 hur Jack Lauderdale months Hafele 4:24 2:2 4:5 2:14,21 13:20,21 10:10 Jeffrey leave morning I half 1.11,17 3:4 8:14 3:20,21 idea 13:20 14:21 4:6 let's motion handed 5:16 JA 8:6 11:11 4:7 6:2 7:6 5:13 9:1 imme

have signed off and said they will not prosecute Mr. Epstein in the Southern District of Florida for any offe

ger, gOOd morning. And Hr. Berger, your client is E -- HR. BERGER: E.W., yes. THE COURT: Anybody else here? MR. EDWARDS: Brad Edward■ on behalf of E.N. as well, Judge. Thanks. EFTA00233748 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Proceedings June

N THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA E.N., CASE NO. 502008CA028058,OOO(MB AD Plaintiff, v. JEFFREY EPSTEIN, Defendant. NOTICE OF TAKING VIDEO DEPOSITION To: See Service List below PLEASE TAKE NOTICE that the undersigned attorney will take the depositi

Fax Robert . Critton, Jr. Flori Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) EFTA00728283 E.W. v. Epstein Page 2 E.W. v. Epstein Service List Brad Edwards, Esq. Brad Edwards and Associates, LLC 2028 Harrison Street Suite 202 Hollywood, FL 33020 P

ASE NO. 502008CA028058,OOO(MB AD Plaintiff, v. JEFFREY EPSTEIN, Defendant. NOTICE OF TAKING VIDEO DEPO

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA E.N., CASE NO. 502008CA028058,OOO(MB AD Plaintiff, v. JEFFREY EPSTEIN, Defendant. NOTICE OF TAKING VIDEO DEPOSITION To: See Service List below PL

IN THE CIRCUIT COURT OF THE F l'EENTH JUDICAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA, CRIMINAL DIVISI01% ca STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant. Case Nos.2006.CF9454 AXX NONPARTY &W.'S MOTION TO VACATE ORDER SEALING RECORDS AND UNSEAL RECORDS E.N., a nonparty, moves pursuant t

INAL DIVISI01% ca STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant. Case Nos.2006.CF9454 AXX NONPARTY

DA, CRIMINAL DIVISI01% ca STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant. Case Nos.2006.CF9454 AXX N

OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant. Case Nos.2006.CF9454 AXX NONPARTY &W.'S MOTION TO VACATE ORDER SEALING RECORDS AND UNSEAL RECORDS E.N., a nonparty, moves pursuant to the Rules of Judicial Administration Rule 2.420(dX5) to vacate the order sealing records and unseal two documents in

87 Loftus, E.F. (1994) Tricked by memory. In J. Jeffrey and G. Edwall (Eds). Memory and History: Essays

ng, p. 535-550. Loftus, E. F. (1997, September). Creating false memories. Scientific American, 277, (3), 70-75. • Reprinted in Boyatzis, C. & Junn, E.N. (2000) Child Growth and Development. NY: McGraw Hill, Chapter 8. Loftus, E. F. (1997). Memory for a past that never was. Current Directions in Psyc