Epstein Secrets

305 358-2800 Fax: 305 358-2382 [email protected] [email protected] Counsel for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656 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

ated Cases Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

undersigned attorneys, hereby files his Notice of Withdrawal of Defendant, EPSTEIN'S, Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum (DE 421) and Defendant, EPSTEIN'S, Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum as to Jane Doe no. 4, and

nyan Boulevard, Suite 400 West Palm Beach, FL 33401 Jay Howell, Esq. Jay Howell & Assoc. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 EFTA00725382

ard Suite 250 Jacksonville, FL 32211 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australia

roduction as a shield to turning over documents whose existence is known to the government or is a foregone conclusion. See, e.g. In re Grand Jury Subpoena Duces Tecum Dated Oct. 29, 1992, 1 F.3d 87, 93 (2d Cir. 1993) (rejecting act of production argument because compliance with subpoena requiring production

much broader fashion," weighing the veracity of witnesses and how they may fare under defense attorneys' questioning, he said. Epstein's attorney, Jack Goldberger, said his client committed no crimes. "The reports and statements in question refer to false accusations that were not charged because the Palm Be

uestion refer to false accusations that were not charged because the Palm Beach County state attorney questioned the credibility of the witnesses," Goldberger said. A county grand jury "found the allegations wholly unsubstantiated and not credible," and that's why his client was not charged with sexual a

puters, it is that content which must be particularly described in the subpoena to comply with the reasonableness requirement. See In re Grand Jury Subpoena Duces Tecum Dated November 15, 1993, 846 F.2d 11, 13 (S.D.N.Y. 1994). The subpoenas at issue fail utterly to do so. Rather,- they are overbroad and unpar

it] Lewis Tein 3059 Grand Avenue Suite 340 Coconut Grove , FL 33133 USA 305-442-1101 Fax: 442-6744 Email: [email protected] EFTA00226855 Jack Alan Goldberger [COR LD NTC] Atterbury Goldberger & Weiss. PA 250 Australian Avenue South Suite 1400 West Palm Beach , FL 33401-5012 USA 561-659-8300 Fax: 83

sed Order)(Horowitz. Adam) (Entered: 06/05/2008) 06/13/2008 10 NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of Jeffrey Epstein (Goldberger, Jack) (Entered: 06/13/2008) 06/13/2008 11 MOTION to Set Aside Default by Jeffrey Epstein. (Attachments: # 1 Affidavit of Richard Barnett)(Goldbe

Compel Presidential Women's Center to Comply with Subpoena Duces Tecum and Incorporated Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe 4 by Jeffrey Epstein. (Attachments: # 1 Exhibit A, # 2 Errata B)(Pike, Michael) (Entered: 12/29/2009) 01/04/2010 444 Pla