Epstein Secrets

-80591,09-80656,09-80802,09-81092 ------------------'/ MOTION FOR PROTECTIVE ORDER AS TO THE DEPOSITION OF NADIA MARCINKOV A Third-Party Witness, NADIA MARCINKOV A, by and through her undersigned attorney, Jack A. Goldberger, and pursuant to Fed. R. Civ. P. 26(c), moves for a Protective Order to rescheduled he

, via email and telephone on February 24 and February 25, 2010 detailing the circumstances surrounding the need to reschedule the deposition of Ms. Marcinkova, providing additional available dates wherein both the undersigned and Ms. Marcinkova will be available. Case 9:08-cv-80119-KAM Document 475

0, to another date to be agreed upon by all interested parties. Isl Jack A. Goldberger Jack A. Goldberger, Esq. Attorney for Third-Party Witness, Nadia Marc ink ova Certificate of Service I HEREBY CERTIFY that the foregoing document is being served this day on all counsel of record identified on th

ey.com Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-80119, 08- 80232, 08-80380, 08-80381, 08-80993, 08- 80994 Robert D. Critton, Jr. Burman Critton Luttier & Coleman, LLP 303 Banyan Blvd. Suite 400 561-842-2820 561-844-6929 West Palm Beach, FL 33401 Counsel for Defendant, Jeffrey Epstein Farmer , Jaffe, Wei

on as Jeffrey 15 to which he has no knowledge, 15 Epstein's friend, can you name anybody? 16 So yes, I'm instructing him not to answer, 16 A. Nadia, Sarah; Just people that we see 17 MR. CRIHON: Let me add in rny part, Is that I 17 routinely on the airplane. 18 think•· you're certainly not

ocument 402 Entered on FLSD Docket 11/09/2009 Page 24 of 26 October 6, 2009 135 J. A. I have no Idea. I don'! know. 2 Q. When you say that Nadia Marcinkova was just 3 coming in the picture, INhat's your understanding as to 4 who Nadia Marclnkova is relative to Mr. Epstein? 5 A. l don't know. I don

ea. I don'! know. 2 Q. When you say that Nadia Marcinkova was just 3 coming in the picture, INhat's your

904-680-1238 Fax Co-counsel for Plaintiff West Palm Beach, FL 33401-5012 Fax: 561-835-8691 ~ Co-Counsel for Defendant Jeffrey Epstein BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Blvd., Suite 400 West Palm Be , FL 33401 (561) 842- (561) 84 By: __;,,_,___,~:1---___:...p_ .. '1-:-q_}-__ R e . Critton, Jr. ~(

0119-KAM Document 510 Entered on FLSD Docket 03/29/2010 Page 4 of 8 RICO Case Statement" to argue that the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because of their "involvement in the scheme." See DE #486 at 2. 14. As Jane Doe's RICO claim was dismissed with prejudice, any

at the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because of their "involvement

gue that the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because of their "

Pike ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 303 Banyan Blvd., Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/253-0164 Fax (Counsel/or Defendant Jeffrey Epstein) 7 Case 9:08

nd of C.M.A.'s mother IIIIIIIIIIIIIIIIIIIIIII (Address will be provided upon receipt) Subject matter: Potential victim and friend of C.M.A. 38. Nadia Marcinkova (Address unknown at this time) Subject matter: Associate of Epstein who may have been involved in encounters between Epstein and C.M.A. 6. Plea

Potential victim and friend of C.M.A. 38. Nadia Marcinkova (Address unknown at this time) Subject matter:

ter: Potential victim and friend of C.M.A. 38. Nadia Marcinkova (Address unknown at this time) Subje

uth Australian Avenue Suite 1400 West Palm Beach, FL 33401 Phone: (561)-202-6360 Fax: (561)-828-0983 Attorneys for Sarah Kellen Robert Critton Burman Critton Luttier & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33414 Phone: (561)-842-2820 Fax: (561)-844-6929 Attorneys for Jeffrey Epstein Richard H.

ubject matter. Friend of C.M.A.'s mother 37. (Address will be provided upon receipt) Subject matter: Potential victim and friend of C.M.A. 38. Nadia Marcinkova (Address unknown at this time) Subject matter: Associate of Epstein who may have been involved in encounters between Epstein and C.M.A. (B) A co

Potential victim and friend of C.M.A. 38. Nadia Marcinkova (Address unknown at this time) Subject matter:

ter: Potential victim and friend of C.M.A. 38. Nadia Marcinkova (Address unknown at this time) Subje

ALIOHNSON Plaintiffs Initial Disclosure Page 2 of 12 Subject matter: Plaintiff. 2. Jeffrey Epstein do his attorneys: Robert Critton, Esquire Burman Critton Luttier & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33414 Tel: (561) 842-2820 Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A