Epstein Secrets

JA ET AL. SERVICE LIST Jack Scarola, Esq. Searcy Denney Scarola et al. 16 EFTA00808220 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd.

each Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA 250 Au

uestion of law to be determined by the court under the facts and circumstances of each case.'" Id. (citations omitted) (citing City of Pensacola v. Owens, 369 So.2d 328 (Fla.1979)). Grounds for Reconsideration The detailed and documented facts from Epstein's affidavit quoted below, along with the un

JA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 25 EFTA00799363 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . • Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward B

h, FL 33409 Jack Goldber er, Es . • Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 14

question of law to be determined by the court under the facts and circumstances of each case.'" Id. (citations omitted) (citing City of Pensacola v. Owens, 369 So.2d 328 (Fla.1979)). UNDISPUTED GROUNDS FOR SUMMARY JUDGMENT The well-documented and undisputed facts in existence at the time Epstein file

S TEIN, P.L. GUY A. LEWIS Fla. Bar No. 623740 [email protected] MICHAEL R. TEIN Fla. Bar No. 993522 ATTERBURY, GOLDBERGER & WEISS, P.A. By: Jack A. Goldberger Fla. Bar No. 262013 [email protected] Attorneys for Defendant Jeffrey Epstein 23 Lewis Trin 3059 Guam Avisyt,Sunt 340, Comm, Glow, /toes. 3

hes to ask an appropriate worded question with the proper foundation and predicate, I will certainly allow the client to answer the question. MR. GOLDBERGER: Why don't you just state attorney/client privilege and just be done with it? MR. LEOPOLD: I want the record to be clear. MR. TEIN: You want to

hasis added). In this case, the plaintiffs have tried to whip Jane Doe's original, one- defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 12 Levyk:Ctin M. 3059 GweAvanur,SUOTE 340, Coormul Glo

ot to remember that it was the court that asked the record to be sealed and it was done during the course of the proceedings: said Epstein's lawyer Jack Goldenberger. Deanna Shullman. another attorney, weighed in as well. Shullman, representing the media and the public's right to see what's in those documents.

nment is doing its job," Post attorney Deanna Shullman said. "There is great public interest in how everybody in this case is doing their job." Goldberger argued that the confidential agreement Epstein struck with federal prosecutors shoukl remain confidential. Included in it, Goldberger said, are

l County Funeral Home and Crema- tory Lake Worth. Meisel, Edith, 88, of Boca Raton, died Wednesday Beth Israel Memorial Cha- pel, Delray Beach. Owens, John Robert, 65, of West Palm Beach. died Wednesday. Quattlebaum Funeral Home, West Palm Beach. Service Thesday. Pacelli, Americo George, 96.

ATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served via U.S. Mail on Monday, July 13, 2009, on the following: Jack A. Goldberger, Esq. Attorney For: Jeffrey Epstein 250 Australian Avenue Suite 1400 West Palm 4101 Robert D. Critton, Jr., Michael J. Pike Attorney For: Jeff

Monday, July 13, 2009, on the following: Jack A. Goldberger, Esq. Attorney For: Jeffrey Epstein 250 Austral

dings below, effectively leaving no adequate remedy on appeal." Martin-Johnson, Inc. v. Savage, 509 So. 2d 1097, 1099 (Fla. 1987) (citing Brooks v. Owens, 97 So. 2d 693 (Fla. 1957); Kilgore v. Bird, 6 So. 2d 541 (Fla. 1942)). The latter requirement is jurisdictional—a "'petitioner must establish tha

robable cause. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . Atterbury, Goldberger, & Weiss, PA 29 EFTA00583980 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq.

each, FL 33409 Jack Goldber er, Es . Atterbury, Goldberger, & Weiss, PA 29 EFTA00583980 250 Australian A

be determined by the court under the facts and circumstances 16 EFTA00583967 of each case.'" Id. (citations omitted) (citing City of Pensacola v. Owens, 369 So.2d 328 (Fla.1979)). UNDISPUTED GROUNDS FOR SUMMARY JUDGMENT The reasonable suspicion that gives rise to probable cause for Epstein's suit

e investigators following him to observe his daily activities. I also explained to him that there was a meeting scheduled with ASA . and Attorney Jack Goldberger at Mr. Krischer's office scheduled on June 1, 2006 at 9:00 am. I attempted to call ASA to inform her of the private investigators following Mr a

No • 1-05-000368 (Continued) has been taken off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger. Attorney Goldberger is the attorney of record for Jeffrey Epstein. His previous attorney, Guy Fronstin, has been fired fromL2pEesentation. ASA has been assigned

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Fla. Bar No. 993522 ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 Tel. Fax. By: Jack A. Goldberger Fla. Bar No. 262013 Attorneys for Defendant Jeffrey Epstein 23 Leal:Finn 3059 G9550 Avow. ant 340, [atom! Gam. hors 33233 23 01310 EFTA0023103

No • 1-05-000368 (Continued) has been taken off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger. Attorney Goldberger is the attorney of record for Jeffrey Epstein. His previous attorney, Guy Fronstin, has been fired from representation. ASA Lana Belohlavek has be

hasis added). In this case, the plaintiffs have tried to whip Jane Doe's original, one- defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 12 1...evfitACCFin N. 3059 Gumo Ave nue n 340, Cocewi

TEIN, ESQ. 7 KATHRYN A. MEYERS, ESQ. LEWIS TEIN, PL 8 3059 GRAND AVENUE, SUITE 340 COCONUT GROVE, FL 33133 9 On behalf of the Defendant: 10 JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 11 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 12 WEST PALM BEACH, FLORIDA 33401 13 14 ALSO PRESENT: ON BEHA

No • 1-05-000368 (Continued) has been taken off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger. Attorney Goldberger is the attorney of record for Jeffrey Epstein. His previous attorney, Guy Fronstin, has been fired from representation. ASA Lana Belohlavek has be

hasis added). In this case, the plaintiffs have tried to whip Jane Doe's original, one- defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 12 n 3059 MIAS° Amkut.$44ti 340. CoccoanGtovi,40444343

those words have real meaning by providing a telling example of an inadequate State process: "a state prosecution for assault and battery in a Mr. Goldberger. In short, it is hard to imagine how the recusal of an assistant to the lead prosecutor could have resulted in any advantage to Mr. Epstein; more to

Leflcowitz attaching draft Deferred Prosecution Agreement, Exhibit 32. 17 While federal prosecutors once suggested that Mr. Epstein's retention of Jack Goldberger was intended to trigger the recusal of assistant prosecutor Dahlia Weiss and thereby influence the outcome of the State prosecution, that assertion

rnment had to show that Sims benefited financially from Owen's sexual activity and that Sims knew that (a) force or coercion would be used to cause Owens to engage in a criminal sex act or (b) that Owens was under the age of 18." (emphasis added). The Eleventh Circuit's interpretation of the statute