Epstein Secrets

[email protected] Counsel for Plaintiffs In related Cases Nos. 0840069, 08-80119, 08- 80232, 08-80380, 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. AUerbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 j

for copying, including certain witness interviews. Egg Exhibit "H" Affidavit of Jack Goldberger. Accordingly, the information hand selected by Mr. Goldberger falls under the work-product doctrine as production of same would reveal Mr. Goldberger's mental impressions, thought processes and strategy relati

of $506,847.78 for 5 years of sexual harassment and sexual touching was reasonable). Unfortunately, the parties were unable to reach a agreement. Myers clearly demonstrates that Epstein's offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe

offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe as compared to the allegations in Myers. Moreover, allowing such discovery at this juncture goes against the grain and the law in that Plaintiff has not made a reasonable showing establish

FLSD Docket 05/28/2010 Page 9 of 10 10 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Bradley James Edwards [email protected] Isidro Manuel G

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

kes it clear that there is a compelling need for any net worth discovery not protected by the Fifth Amendment privilege. 5 Defendant relies upon Myers v. Central Florida Investment, Inc., 592 F.3d 1201 (11th Cir. 2010) for its “stipulation” argument. In Myers, however, the district court heard tes

Myers, however, the district court heard testimony regarding each of the defendant’s net worth. There was no unilateral statement of net worth in Myers as Defendant wishes to create in the instant case. To the extent that Defendant relies upon the Court’s holding in Myers regarding the reasonablen

orowitz(alsexabuseattorney.com Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-801 J9, 08- 80232, 08-8038~ 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691

for copying, including certain witness interviews. See Exhibit "H" Affidavit of Jack Goldberger. Accordingly, the information hand selected by Mr. Goldberger falls under the work-product doctrine as production of same would reveal Mr. Goldberger's mental impressions, thought processes and strategy relati

ures. Such a stipulation more than satisfies any necessity for the disclosure of the tax returns or any additional net worth information. See e.g., Myers v. Central Florida Investments, Inc., 592 F.3d 1201 (I Ith Cir. 2010)(reasoning that a compensatory award of $103,622.09 and a punitive damage award

of $506,847.78 for 5 years of sexual harassment and sexual touching was reasonable). Unfortunately, the parties were unable to reach a agreement. Myers clearly demonstrates that Epstein's offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe

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

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

Amendment privilege. 5 Defendant relies upon Myers v. Central Florida Investment, Inc., 592 F.3d 120

here was no unilateral statement of net worth in Myers as Defendant wishes to create in the instant case

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

ar-old Jason Roden of Loxahatchee. "He was a wonderful boy, and he did a lot for 111 ;29.9.3 • Absolut Vodka I Three Olives • -- '24.99 Myers Platinum Rum $1659 $ Chivas — Regal '49.99 The I $ , Macallan J‘. • 39.99 g Early lime • Canadian Mist .. 46.99 Wild Turkey '29

uld call a lawyer. The letter also mentioned Jack Goldberger, who I knew to be Epstein's attorney, which scar

sh that the Government had told me that was what was really going on. 38. I saw on the letter that I could call a lawyer. The letter also mentioned Jack Goldberger, who I knew to be Epstein's attorney, which scared me. I first got in touch with the attorneys at the Podhurst Orseck firm My lawyers filed a lawsu

on remains sound public policy is beside the point. Courts do not exist to "update" statutes in light of the latest technological developments. See Myers'. Toolay's d4gnu. Corp., 640 F.3d 1278. 1286 (11th Cir. 2011) (courts "are not licensed to practice statutory remodeling"); Wright. Sec 'y for Dept

k crim- inal defense attorney. provided some of those Su EPSTEIN, 78 P. • te4 EFTA01689478 • Epstein paid girl 0- EPSTEIN front docurrients to Goldberger. "Jeffrey Epstein did not have sex with this woman," Sanchez said. Herman suggested that Epstein masturbated in front of the alleged victim and

other copycat lawsuit filed by the same lawyer who appears less interested in the truth than in grandstanding with these press conferences: said Jack Goldberger, one of Epstein's attorneys. We now have sworn testimony that girls lied about their age to Jeffrey Epstein, and they were care- ful in being con

y provided the following information: On November 2, 2007, private inves ' r Robert Myers and a Hispanic, well dressed fe led s resid Initially Myers was asking for and another name ' iiiim could not recall, before he sai Myers was wor • behalf of attorney's for Jeffrey s e n. Myers asked if

es to blunt an incipient new wave of cases with its vaccination campaign." Administration Facing Fourth Wave With Limited Options. Politico (3/30, Goldberg, 6.73M) reports that the Biden Administration "is confronting its first surge of Covid- 19 with few public health options and even some of its Democr

topher Myers was acquitted of a deprivation of rights count, "but the jury could not reach a verdict on a charge of destruction of evidence against Myers for allegedly smashing Hall's cellphone. The jury also deadlocked on the deprivation of rights charge against former officer Dustin Boone." Fox New

2265 File folder entitled "JEGE & Hyperion from Goldberger OLY-46 & OLY-47" containing documents received i

ney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.14 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe

were already pending against lender in bankruptcy adversary proceeding. Fed. Rules Civ.Proc.Rule 23(bX3), 28 U.S.C.A. ARGUED: Daniel P. Shapiro, Goldberg, Kohn, Bell, Black, Rosenbloom & Moritz, Ltd, Chicago, Illinois, for Appellant. Gil- bert Scott Bagnell, Bagnell & Eason, L.L.C., Columbia, South

oint of being incomplete" and ask this court to vacate it and remand the case for further consideration. In support of that request, they rely on Myers v. Gulf Oil Corpora- tion,' in which we held that a district court's explanation that the defendant should be granted summary judgment "be- cause t