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y to see then-State Attorney Barry Krischer kick the case to a grand jury. Mr. Krischer backed off when one of Epstein's gold-plated attor- neys, Alan Dershowitz, announced that some of the victims had posted MySpace comments about their alco- hol and marijuana use. Epstein's "best" defense has been that h
n one of Epstein's gold-plated attor- neys, Alan Dershowitz, announced that some of the victims had posted
f when one of Epstein's gold-plated attor- neys, Alan Dershowitz, announced that some of the victims h
ere 34 percent lower than a year ago. "Stimulating sales is the only way to get the auto industry back on its led," said Rep. Donald Manzullo, General Motors Corp. and Chrysler LLC have received billions of dol- lars in government aid and the entire auto indus- try has watched car sales plummet during the pa
I 0 ./ Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Co-Counsel for Defendant Jeffrey Epst
settled that a Defendant may take the deposition of a ma and/or a witty-cc before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and lave v. General Motors Corp., 43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2-7 commenced separate civil actions upon the filing of same against Jeffrey Epstein. Therefore, Def
f the Court deems just and proper. By: Is/ Jack Alan Goldberger Florida Bar No. 262013 6 EFTA007281
ts or representatives of a party's attorney. 12. The attorney-client privilege also extends to subordinates of a party's attorney. See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege
istrict Court, Southern District of Florida Jack Alan Goldber er, Es . Isidro Manual Garcia Mi h I m
er home (or, if necessary, other place of safety) without facing the threat of any further harassment or intimidation. See Serra Chevrolet, Inc. v. General Motors Corp., 446 F.3d 1137, 1147 (11th Cir. 2006) ("Civil contempt may be imposed in an ordinary civil proceeding upon notice and an opportunity to be heard.")
Entities connected to both Alan Dershowitz and General Motors Corp.

Jeffrey Epstein
PERSONLeon Black
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Kenneth Marra
PERSONMartin Weinberg
PERSONRobert D. Critton
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
George Mitchell
PERSONMichael J. Pike
PERSON
New York
LOCATIONScott Rothstein
PERSON