Epstein Secrets

age 5 attached Exhibit "A", Affidavit of Jack A. Goldberger, a board certified criminal defense attorney who

e copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Jack Alan Goldberger Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 34 of 37 Jane Doe No. 2 v. Epstein Page 33 Clearly, the nature o

a particularized inquiry, evaluating whether the privilege applies with respect to each specific area that the questioning party wishes to explore. Melchor Moreno. 536 F.2d at 1049. The witness may be totally excused from testifying only if the court finds that he could legitimately refuse to answer essential

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

ed on FLSD Docket 04/20/2009 Page 10 of 11 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] s/ Stuart S. Mermelstein

”, and “only as to genuinely threatening questions should [the witness’s] silence be sustained.” Goodwin, 625 F.2d at 701 (quoting United States v. Melchor Moreno, 536 F.2d 1042, 1049 (5th Cir. 1976)). Defendant further asserts that Plaintiff’s interrogatories requesting that he identify employees may lea

egan approaching the State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by t

f attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.

ss's silence is justified. United States v. Koubriti , 297 F. Supp. 2d 955, 962 (ED. Mich. 2004) (citing Hoffman , 341 U.S. at 53; United States v. Melchor Moreno , 536 F.2d 1042, 1049 (5th Cir. 1976); United States v. Rue , 819 F.2d 1488 (8th Cir. 1987); In re Morganroth , 718 F.2d 161, 167 (6th Cir. 1983)).

ct Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton,

Entered on FLSD Docket 04/20/2009 Page 11 of 11 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] s/ Stuart S. Mermelstein EFTA00221731

ry", and "only as to genuinely threatening questions should [the witness's] silence be sustained." Goodwin, 625 F.2d at 701 (quoting United States'. Melchor Moreno, 536 F.2d 1042, 1049 (5th Cir. 1976)). Defendant further asserts that Plaintiff's interrogatories requesting that he identify employees may lead t

age 5 attached Exhibit "A", Affidavit of Jack A. Goldberger, a board certified criminal defense attorney who

e copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Jack Alan Goldberger EFTA00222107 Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 34 of 37 Jane Doe No. 2 v. Epstein Page 33 Clearly, t

a particularized inquiry, evaluating whether the privilege applies with respect to each specific area that the questioning party wishes to explore. Melchor Moreno, 536 F.2d at 1049. The witness may be totally excused from testifying only if the court finds that he could legitimately refuse to answer essential

egan approaching the State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by t

f attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.

ness's silence is justified. United States I Koubriti , 297 F. Supp. 2d 955, 962 (ED. Mich. 2004) (citing Hoffman , 341 U.S. at 53; United States I Melchor Moreno , 536 F.2d 1042, 1049 (5th Cir. 1976); United States I Rue , 819 F.2d 1488 (8th Cir. 1987); In re Morganroth , 718 F.2d 161, 167 (6th Cir. 1983)). S

d solicitation offense is a felony. -3- EFTA00179102 pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.' As explained in the Declaration of Epstein knew of the state investigation by the first week of

attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.'

ss's silence is justified. United States v. Koubriti, 297 F. Supp. 2d 955, 962 (E.D. Mich. 2004) (citing Hoffinan, 341 U.S. at 53; United States v. Melchor Moreno, 536 F.2d 1042, 1049 (5th Cir. 1976); United States v. Rue, 819 F.2d 1488 (8th Cir. 1987); In re Morganroth, 718 F.2d 161, 167 (6th Cir. 1983)). See