Epstein Secrets

Y, GOLDBERGER & WEISS 17 Co-Counsel for Defendarus One Clearbke Court 18 Suite 1400 West Palm Beach. Florida 33401 19 Tel: (561)659.8300 BY: JACK A. GOLDBERGER. ESQ. 20 21 22 23 24 25 ALSO PRESENT: JESSICA CADWELL JOE ROVNER. Videographer (U.S. Legal) 3 1 The videotaped deposition of — 2 in the

er your question, I must invoke my Fifth and Sixth Amendment privileges and refuse to answer your questions. Q What is your current address? MR. GOLDBERGER: There is going to be a continued, obviously, you anticipate I'm sure, continued invocation of Fifth 2 (Pages 2 to 5) U.S. Legal Support (561) 8

Australian Avenue South West Palm Beach. Oxide 33901 8 9 10 ATIENTION: JACK GOLDBERGER. ESQ. In Re: DOE EPSTEIN Depositica at _- 11 12 One Mt Goldberger. 13 Since counsel have agreed that you nay have the witness read and sip your copy of the 19 deposition, far your conthoience, withal herewith

Did you know that at the time she was visiting Mr. Epstein and providing massages, she was under the age of 18? MR. YAREMA: Object to the form. A Firth. Q Do you recall being introduced to A.D. by Mr. Epstein? MR. YAREMA: Object to the fonn. A Fifth. Q Do you recall that Jeffrey Epstein instruc

er burden if he were suing for defamation, he should be afforded more latitude in responding when others allegedly defame him. In Sullivan Justice Goldberg illuminated some of the concerns the Court was targeting, writing, "[T]he Constitution accords citizens and press an unconditional freedom to crit

ck") (quotations omitted, emphasis added). The single publication rule has been adapted to r blications on the Internet under a similar rationale. Firth v. State, 98 N.Y.2d 365, 370, 747 N.Y.S.2d 69, 775 N.E.2d 463 (N.Y. 2002). In adapting the rule to the Internet, the New York Court of Appeals reco

d of advice of counsel defense. THE COURT: Would you tell me who those attorneys are, please? MR. SCAROLA: Mr. Roy Black is one, and I think Mr. Goldberger was another. MR. GOLDBERGER: Yes, Mr. Goldberger is one of them. Mr. Critton is one and Mr. Akerman. MR. SCAROLA: Mr. Critton and Palm Beach Rep

ight there, Your Honor. I can say that -- THE COURT: Join the club. MR. BREWER: I can say that because of the incendiary case, he has to pled the Firth to certain questions which deal with Palm Beach Reporting Service, Inc. EFTA00788345 235 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17