Epstein Secrets

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

r conversations with hei· supervising partner as the questions invaded the attorney-client privilege). 14. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi

Bar No. 262013 i [email protected] Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite

cord identified on the following Service List in the manner specified by CM/ECF on this_ day of November, 2009 Respectfully submitted, By:-------- JACK ALAN GOLDBERGER ESQ. Florida Bar No. 262013 i [email protected] Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL

d beyond September of 2005. Therefore whatever information Mr. Zinoview may have, postdates that time. 5. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi

08-8038~ 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

[email protected] Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-80119, 08- 80232, 08-8038~ 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

opriate and irrelevant and not reasonably calculated to lead to the discovery of admissible evidence." 24. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order,2 "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson

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

er conversations with her supervising partner as the questions invaded the attorney-client privilege). 14. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. & William