Epstein Secrets

ez, Fowler White Burnett, Miami, FL; (5) Jack A. Goldberger, Goldberger & Weiss, West Palm Beach, FL; and (6)

Miami, FL; (3) Gerald B. Lefcourt, Law Office of Gerald B. Lefcourt, P.C., New York, NY (4) Lilly Ann Sanchez, Fowler White Burnett, Miami, FL; (5) Jack A. Goldberger, Goldberger & Weiss, West Palm Beach, FL; and (6) Joe D. Whitley, Alston & Bird, Washington D.C.; as well as Harvard Law Professor Alan Dershowitz.

t for Sixth Amendment right-to-counsel purposes, that a "prosecution" does not begin with the criminal complaint's filing. See P. United States v. Alvarado, 440 F.3d 191, 199-200 (4th Cir. 2006) ("The filing of a federal criminal complaint does not commence a formal prosecution."); see also, e.g., ‘I

r cases were still under investigation. Tr. July I I, 2008 at 4-6, 18-19, 22-23. 42. On June 30, 2008, the U.S. Attorney's Office sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, reflecting continuing efforts to keep the NPA secret: 19 EFTA00177027 Case 9:08-cv-80736-KAM Document 48

the U.S. Attorney's Office sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, reflectin

ation of adversary judicial proceedings against the defendant," than can the filing of an affidavit in support of a search warrant. United States' Alvarado, 440 F.3d 191, 200 (4th Cir. 2006) (quotia United States. Gouveia, 467 U.S. 180, 187, 189) (emphasis added). See also United States I Langley, 848 F

from Guy Fronstin to Assistant State Attorney dated4-6-06. 86. Letter from Guy Fronstin to Assistant State Attorney dated4-10-06. 87. Letter from Goldberger dated 6-22-06. Also objected to as possible attorney/client privilege as there is no other identifying information regarding this letter, such as it

ents about Epstein who is party to, and possible witness in, this case, rendering it improper opinion testimony about the credibility of a witness. Alvarado v. State, 521 So. 2d 180 (Fla. 3d DCA 1988). In Childers v. State, 936 So. 2d 585 (Fla. 1st DCA 2006), the court was faced with a similar issue, and