Epstein Secrets

cuments responsive to this Request. DOCUMENT REOUEST NO. 11 Produce any documents concerning any of Your attorneys' or agents' communications with Alan Dershowitz's attorneys or agents from 1999 to the present RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or information protecte

ge, the work-product doctrine, the common interest privilege or any other applicable privilege. Defendant is withholding communications between Mr. Dershowitz's counsel and Defendant's counsel which contain work product and concern joint defense or common interest matters. DOCUMENT REOUEST NO. 12 Produce

nt Defense Agreement entered into between You and Alan Dershowitz from 1999 to the present. RESPONSE:

form of a Request for Production of Documents and is 4 EFTA00091356 a contention Interrogatory barred according to Plaintiff's interpretation of the Local Rules. The Request embeds a number of assumptions that are not true and for which Plaintiff supplies no basis for assertion of their veracity. Ms. Maxwe

9102 pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.' As explained in the Declaration of Epstein knew of the state investigation by the first week of October, 2005. On October 18, 2005, a search war

Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.' As explained in the Declaration of Epstein kn

Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.' As explained in the Declaration of

without being forced to disclose the status of the grand jury investigation and the matters occurring before the grand jury to Epstein. Pursuant to the Local Rules, the undersigned has conferred with counsel for Intervenor Epstein, who has advised that he opposes the granting of this motion. WHEREFORE, the Uni

istrict Court, Southern District of Florida Jack Alan Goldberger [email protected] Michael R. Tein

ng the Motion to Stay. See S.D. Fla. L. R. 7.1.A.3. Notably, Defendant's Motion also contains no certification as to any such attempt as required by the Local Rules. See id. The Local Rules provide that the "fflailure to comply with the requirements of this rule may be cause for the court to grant or deny the m

RNEY ATTORNEY TO BE NOTICED represented by Jack Alan Goldberger Atterbury Goldberger &Weiss, P.A. 25

a timely manner within ten (10) days from the date of entry of this Order. Plaintiff may respond to Defendant's report within the time allotted by the Local Rules. Failure to respond to this Order shall result in an entry of default against Defendant. DONE AND ORDERED in Chambers at West Palm Beach, Palm Beac