Epstein Secrets

live(d) as underage prostitutes in condos owned by Epstein" (191 65; see also 62-67); Edwards' rationalization as to why he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for deposition en 70-75); purported relevancy of pilot and flight logs to show interstate airp

alization as to why he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richar

ationalization as to why he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and

asked solely to poison the wel1.6 The Court recently sustained Plaintiffs objections to discovery requests geared solely to alleged sexual activity (D.E. 148, 149, and 150). Accordingly, the sword and shield doctrine does not apply to the illegitimate and irrelevant questions which Plaintiff declined

ndrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and R

nce Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefko

ment, including efforts by former President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00179727 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docke

vilege log with its objections annotated (D.E. 224-1); (2) a motion to compel production of documents that are not privileged, numbering eight pages D.E. 225; (3) a twenty-four page, single-spaced affidavit of petitioners' counsel, addressing the EFTA00179785 Case 9:08-cv-80736-KAM Document 230 Ent

by CM/ECF on this t5 day of March, 2010: Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

retrial motions by the parties is March 5, 2010. This action is currently set for trial on the two week calendar commencing Monday, July 16, 2010. [D.E. 119]. Thus, in order to comply with the Court's order, Defendant is filing the subject motion now. As stated above, Defendant requests and reserves

fe, Weissing, Edwards, Fistos & Lehrman PL Jack Alan Goldberger, Esq. Aueroury uotaneriter K weirs, r

note from a review of the docket sheet in Doe v. U.S., that Judge Marra administratively closed the cases for non-prosecution on September 9, 2010 [D.E. 39]. Please recall the undersigned pointed out in Epstein's initial motion that this case has been languishing in excess -6- FOWLER WHITE BURNETT.

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

million - - well over the $75,000 amount-in-controversy requirement for diversity jurisdiction. See Jane Doe No. 2 at D.E. 1 ¶ 4; Jane Doe No. 3 at D.E. I ¶ 4; Jane Doe No. 4 at D.E. 1 ¶ 4; Jane Doe No. 5 at D.E. 1 ¶ 4. 3. There is complete diversity. Diversity jurisdiction requires complete divers

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

EPSTEIN upon her, Plaintiff intends to rely exclusively on the statutory damages, rather than those damages which are available at common law. (See D.E. 113). If however, the Court rules that the statutory floor applies only one time, regardless of the number of times EPSTEIN committed an enumerated

e No. 08-08804 Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

s extended. In light of Plaintiffs filing of her Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided by 18 U.S.C. §2255 (D.E. 113) on June 5, 2009, Plaintiff agrees to a modification of the pretrial schedule as outlined in Defendant EPSTEIN's Motion to Strike (D.E. 104); to