Epstein Secrets

reading of that document, the press release by Barden and Gow, is that she's talking about the allegations against her, Maxwell, and she includes Dershowitz, and that's essentially it. I mean, she's not parsing through the 102 pleading and saying, you know, this is wrong and that is wrong. And the funda

22 23 24 25 problem. Well, no, it isn't. No, it isn't. Okay. So let's do 675. MS. MENNINGER: Your Honor, I will say that it is my reading of Rule 412 that any hearing that is based upon in part Rule 412 is supposed to be conducted in a in camera setting. MS. SCHULTZ: Counsel for Ms. has no objec

istrict Court, Southern District of Florida Jack Alan Goldber er Es . Robert D. Critton, Es . Bradley

9-KAM Document 266 Entered on FLSD Docket 08/14/2009 Page 7 of 9 history, thereby evading the limitations on discovery and admissibility found in Rule 412 for the only conceivable purpose of harassing the Plaintiff. Defendant asserts that he seeks to use investigators to ask ex-boyfriends and friends

ikely be presented at trial."); see also Charles Alan Wright & Arthur R. Miller, 23 Fed. Prac. & Proc.

)(2). EFTA00065523 Case 1:20-cr-00330-AJN Document 351 Filed 10/15/21 Page 3 of 4 Page 3 "Given that the hearing provides an opportunity for the Rule 412 movant to detail the evidence he seeks to admit and for the parties to discuss the propriety of its admission, the notice requirement should be see

tz, P.A. Counsel for Plaintiff Jane Doe #1 Jack Alan Goldberger Atterbury Goldberger & Weiss. P.A. C

conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu

FL 33160 Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 2

conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu

istrict Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D

urt "must impose certain restriction on discovery to preclude inquiry into areas which will clearly fail to satisfy the balancing test" set forth in Rule 412. See Barta I. City and County of Honolulu, 169 F.R.D. at 135. In Barta, the Court confronted this issue in the context of a discovery motion in a c

joint 16 defense agreement issue just raised by Mr. Edwards. 17 You're going to see a pleading later today that is 18 going to have the actual Dershowitz transcript testimony in 19 this, and this is now, again, I say lawyer testimony here, 20 unsupported by the facts. There is no joint defense agre

same 2 problem. Well, no, it isn't. No, it isn't. 3 Okay. So let's do 675. 4 MS. MENNINGER: Your Honor, I will say that it is my 5 reading of Rule 412 that any hearing that is based upon in part 6 Rule 412 is supposed to be conducted in a in camera setting. 7 MS. SCHULTZ: Counsel for Ms. has no

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

l conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu