Epstein Secrets

While investigations by other plaintiffs' attorneys and I have uncovered other persons who were acquaintances of Epstein, specifically David Trump, Alan Dershowitz, Bill Clinton, Tommy Mottola, and David Copperfield, we have no information that any of those people (other than Mr. Dershowitz) have spoken to Eps

y David Trump, Alan Dershowitz, Bill Clinton, Tommy Mottola, and David Copperfield, we have no information that any of those people (other than Mr. Dershowitz) have spoken to Epstein about Jane Doe or any of the other victims of Epstein's molestation. Mr. Dershowitz is acting as an attorney for Epstein, an

ws Ave., Suite 2, Fort Lauderdale, FL 33301 Jack Alan Goldberger, Esq., 250 Australian Avenue South, Su

Mr. Rush's interview of Mr. Epstein. (Fisten Aff., Apr. 23, 2010 [Real Party in Interest Jane Doe's Resp. in Opp'n to Mot. of Daily News, L.P., to Quash Subpoena, Ex. B] 1 3.) Mr. Rush paraphrased the interview relatively thoroughly. (Id. 1 7.) 4. As noted above, the present motion has been argued on the

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

PURPOSES OF DISCOVERY Plaintiff, by and through undersigned counsel, files this Reply Memorandum In Support of Motion for Protective Order, and to Quash Subpoena, and Motion to Consolidate for Purposes of Discovery, as follows: I. DEFENDANT FAILS TO SET FORTH ANY PREJUDICE OR CONFUSION THAT WOULD MILITATE

ayne Boulevard Suite 2218 Miami , FL 33160 Jack Alan Goldberaer ATTORNEY TO BE NOTICED Atterbury Gol

rt in case 9:08-cv-80119-KAM; granting (65) Motion for Extension of Time to Respond re (66 in 9:08-cv-80119-KAM) MOTION for Protective Order and to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate Cases for Purposes of Discovery, and Incorporated Memorandum of Law in Support in case 9:08-

rcia(a:bellsouth.net Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

4/13/2009 32 ENDORSED ORDER granting (73) Motion for Extension of Time to Respond re (66 in 9:08-cv-80119-KAM) MOTION for Protective Order and to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate Cases for Purposes of Discovery, and Incorporated Memorandum of Law in Support in case 9:08

1-828-0983 Email: [email protected] Gins Alan I awic [COR LD Nit] Lewis Tein 3059 Grand Aven

. (Pike, Michael) (Entered: 04/06/2009) ENDORSED ORDER granting 71 Motion for Extension of Time to Respond re 66 MOTION for Protective Order and to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate Cases for Purposes of Discovery, and Incorporated Memorandum of Law in Support . Responses d