Epstein Secrets

.com [email protected] Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

[email protected] Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

e legal consequences of their actions. FN18. See General Motors Corp. v. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105, 11

[email protected] Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

useattorney.com Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

e legal consequences of their actions. FNl8. See General Motors Corp. v. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105, 11

2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected] [email protected] Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jagesq

com Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australi

ttled that a Defendant may take the deposition of a party and/or a witness before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and Leve v. General Motors Corp., 43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2 and 3 commenced separate civil actions upon the filing of same against Jeffrey Epstein. Therefore,

ched as Exhibit A). 2. Mr. Cowles was hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on I July 16, 2008 and has been employed by Mr. Goldberger since that time. Mr. Cowl.es was hired as Mr. Goldberger's law office assistant to be directly involved only with Mr. Epstein's case while he was s

enter a protective '" order prohibiting the deposition of Story Cowles and grant any additional relief the Comi deems just and proper. 6 By: /s/ Jack Alan Goldberger Florida Bar No. 262013 Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 7 of 8 Certificate of Service I HEREBY C

s attorney. 12. The attorney-client privilege also extends to subordinates of a party's attorney. -- - - - - - ··- --·· -· -- . -- See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege

CF on this ft day of , 2009: Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz. P.A. Counsellor Plaintiff Jane Doe 03 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. Cd-Counsel for Defendant Jeffrey Epstein EFTA00722751 Page 7 Respectfully submitted, By: ROBERT D. CRITTON

./ Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Co-Counsel for Defendant Jeffrey Epstein EFTA00

settled that a Defendant may take the deposition of a ma and/or a witty-cc before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and lave v. General Motors Corp., 43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2-7 commenced separate civil actions upon the filing of same against Jeffrey Epstein. Therefore, Def

Court enter a protective order prohibiting the deposition of Story Cowles and grant any additional relief the Court deems just and proper. By: Is/ Jack Alan Goldberger Florida Bar No. 262013 6 EFTA00728109 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with t

ttached as Exhibit A). 2. Mr. Cowles was hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on July 16, 2008 and has been employed by Mr. Goldberger since that time. Mr. Cowles was hired as Mr. Goldberger's law office assistant to be directly involved only with Mr. Epstein's case while he was se

ts or representatives of a party's attorney. 12. The attorney-client privilege also extends to subordinates of a party's attorney. See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege

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

ere 34 percent lower than a year ago. "Stimulating sales is the only way to get the auto industry back on its led," said Rep. Donald Manzullo, General Motors Corp. and Chrysler LLC have received billions of dol- lars in government aid and the entire auto indus- try has watched car sales plummet during the pa