Epstein Secrets

statement was made with “actual malice—that is knowledge that it was false or with reckless disregard of whether it was false or not.” I was Justice Goldberg’s law clerk when the Supreme Court rendered that precedent-shattering decision. Goldberg told me that he was concerned that the daunting requirements

ns, he didn’t feel they were right for the job. They worked together through scholarship and advocacy against the death penalty for the remainder of Goldberg’s life. It is difficult to imagine that Goldberg could have found a more willing and able confederate than Alan Dershowitz. 159 HOUSE_OVERSIGHT_017

authored by Louis Brandeis, who eventually became one of the “founding fathers” of the 20" Century rebirth of the First Amendment. As a young lawyer, Brandeis was concerned about how local tabloids were publishing gossip about prominent people, including members of his own partner’s family. He and his partn

“be let alone,” which they analogized , at least superficially, to the law of defamation. Remarkably, especially in light of subsequent developments, Brandeis did not seem particularly sensitive to how his new right of privacy might conflict with the old right of the press to publish scandalous material. T

e 21 of 41 CASE NO: 08-CV-80119-MARRA/JOHNSON SERVICE LIST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Isidro Manual Garcia isid [email protected] Jack Patrick Hill ip

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

t 06/19/2009 Page 10 of 41 CASE NO: 08-CV-80119-MARRA/JOHNSON The silence in the face of these questions speaks far louder than words. As Justice Brandeis recognized long ago, "[s]ilence is often evidence of the most persuasive character."' Baxter v. Palmigiano, 425 U.S. 308, 319 (1976) (quoting U.S.

Shipley West Palm Beach, FL 33409 By: Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbu Goldber er et al. West Palm Beach, FL 33401 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik Fort Lauderdale, FL 33301 Gary M. F

URNETT P.A. West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbu Goldber er et al. West Palm Beac

ity and Inv. Corp., 615 So.2d 841, 842 (Fla. 4th Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumsky v. Tod 263 U.S. 149, 153-154 (1923) (Brandeis, J.). In the circumstances of this case, a reasonable finder of fact would have "evidence of the most persuasive character" from Epstein's repeated

rity and Inv. Corp., 615 So.2d 841, 842 (Fla. 4" Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumsky v. Tod, 263 U.S. 149, 153-154 (1923) (Brandeis, J.). In the circumstances of this case, a reasonable finder of fact would have "evidence of the most persuasive character" from Epstein's repeated r

ed rejection. In addition, as will be privately explained at mediation, Epstein's day of public reckoning is inevitable. Cc: Bradley Edwards, Esquire Jack A. Goldberger, Esquire Fred Haddad, Esquire Marc S. Nurik, Esquire Tonja Haddad Coleman, Esquire i SEES SIN HOUSE_OVERSIGHT_029323

inevitable. Cc: Bradley Edwards, Esquire Jack A. Goldberger, Esquire Fred Haddad, Esquire Marc S. Nurik, Esqu