Epstein Secrets

istrict Court, Southern District of Florida Jack Alan Goldberger Es . Robert D. Critton, Esq. s/ Adam

t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi

n Related Cases Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

, P.A.'S RESPONSE TO DEFENDANT'S EMERGENCY MOTION FOR ORDER FOR THE PRESERVATION OF EVIDENCE [D.E. 405) The Honorable Herbert Stettin ("Stettin"), the State Court appointed' receiver ("Receiver") and Chief Restructuring Officer ("CRO") of Rothstein Rosenfeldt Adler, P.A.'s ("RRA"), hereby responds to the Defe

in Related Cases Not 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

, P.A.'S RESPONSE TO DEFENDANT'S EMERGENCY MOTION FOR ORDER FOR THE PRESERVATION OF EVIDENCE [D.E. 405) The Honorable Herbert Stettin ("Stettin"), the State Court appointed' receiver ("Receiver") and Chief Restructuring Officer ("CRO") of Rothstein Rosenfeldt Adler, P.A.'s ("RRA"), hereby responds to the Defe

Florida Bar (VIA EMAIL) Adria E. Quintela, Esq. Alan Anthony Pascal, Esq. Lake Shore Plaza II 1300 C

materials which the Circuit Court would not allow. See Epstein's Motion to Compel, DE 807. III. Memorandum of Law A. Discovery Issues Related to the State Court Issued Subpoena Arc Not Properly Before the Bankruptcy Court Despite Epstein's stated position to the contrary, neither 28 U.S.C. §§ 152 or 1334 co

EMAIL) The Florida Bar Adria E. Quintela, Esq. Alan Anthony Pascal, Esq. Lake Shore Plaza II 19 EF

relevance, burdensomeness, and attorney-client and other privileges regarding the Razorback Creditors' subpoena. Instead, these issues are left to the State Court judge presiding over their case to decide. I. BACKGROUND The procedural background surrounding the Razorback Creditor's motion is important to t

nlaw.com Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 2

t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi

nlaw.com Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 2

t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi

stein Served via U.S. Mail, postage prepaid Guy Alan Lewis, Esq. Email: [email protected] Lewis Te

seized Evidence identified in Ex. A, to Exhibit 1 of this Motion (Palm Beach Police Department Property Receipt) should it be Returned to EPSTEIN by the State Court, and EFTA00234456 Case 9:08-cv-80804-KAM Document 12 Entered on FLSD Docket 08/21/2008 Page 2 of 5 expedite the duplication of this evidence i

Email LEAD ATTORNEY ATTORNEY TO BE NOTICED Guy Alan Lewis Lewis Tein 3059 Grand Avenue Suite 340

#12 in the case of JANE DOE, a/k/a. JANE DOE NO. 1 v. JEFFREY EPSTEIN et al. Case NO.08-80804-CIV-MARRA/JOHNSON should it be Returned to EPSTEIN by the State Court, and expedite the duplication of this evidence immediately upon its return, in advance of any Rule 26 conference. EFTA00175478 Case 9:08-cv-86, .

melstein Es ounse • r aintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss. P.A. C

t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi