Epstein Secrets

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

on FLSD Docket 04/27/2010 Page 7 of 8 8 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

fe or her daughter making a video. See Exhibit 4, deposition excerpt of Jane Doe No. 4’s mother. 7. Defendant now wants to take the deposition of Rocky Orezzoli, Jane Doe No. 4’s college soccer coach, and Bill Brown, Doe No. 4’s soccer coach in middle and high school. The past conduct of Epstein’s counsel

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

ered on FLSD Docket 05/05/2010 Page 4 of 5 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

and states as follows: 1. Plaintiff Jane Doe No. 4’s Motion for Protective Order (“Motion”) is now moot, in part, with regard to the deposition of Rocky Orezzoli, as Mr. Orezzoli was deposed by Defendant Epstein’s counsel on April 30, 2010, while the Motion was pending. However, the Motion remains ripe with

[email protected] Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 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

8-80380, 08-80381, 08-80993, 08-80994 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

discovery and thus preventing Epstein from deposing third parties, including two individuals that were Jane Doe 4's soccer coaches for years (i.e., Rocky Orezzoli and Bill Brown). Limiting such discovery would undoubtedly result in reversible error. Plaintiff claims Epstein is harassing her by way of seeking