Epstein Secrets

ortions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and deny their motion

orneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys as

heir failure to seek a prompt resolution of the case. However, in light of the Court's Order, it would seem that this issue is better resolved in a Motion for Reconsideration or on appeal of that ruling rather than in this Supplemental Briefing. Accordingly, the Intervenors' third argument is not addressed herein. 5 EFT

g was sent by fax and U.S. Mail to the following addressees on this 14th day of September, 2009: Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Leo Jack Goldberger, Esq. ss, P.A. Fax: Co-counsel for Defendant Jeffrey Epstein BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Blvd., Suite 400 FL 33401 By:

vin, Esq. (via facsimile w/o enclosures) Jack A. Goldberger, Esq. (via facsimile w/o enclosures) • PHONE: •

e 5 of 8 the objection 'so general and sweeping in nature" that they aamount[ed] to a blanket assertion of the privilege: Id. p.11. In the instant Motion for Reconsideration, Epstein has set forth additional facts and detailed reasoning successfully demonstrating how forcing him to answer these requests would realistica

ortions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and deny their motion

orneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys as

heir failure to seek a prompt resolution of the case. However, in light of the Court's Order, it would seem that this issue is better resolved in a Motion for Reconsideration or on appeal of that ruling rather than in this Supplemental Briefing. Accordingly, the Intervenors' third argument is not addressed herein. 5 EFT

ICE LIST CASE NO. 502009CA040800300CXMBAG Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd.

each Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA 250 Au

, FL 33301. EFTA00613846 Reconsideration. Three months later, Edwards has filed this purported "supplemental authority" in support of his initial Motion for Reconsideration. However, this supplemental authority" does nothing more than establish the fact that another trial court, just as this Court did in the case at h

Copy furnished: JACK SCAROLA, ESQUIRE, JOSEPH L. ACKERMAN, ESQUIRE MARC NURIK, ES Ul E FARMER, JAFFE, JACK A. GOLDBERGER, ESQUIRE, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY CIVIL DIVISION CASE NO.: 502009CA040800

IRE MARC NURIK, ES Ul E FARMER, JAFFE, JACK A. GOLDBERGER, ESQUIRE, IN THE CIRCUIT COURT OF THE FIFTEENTH

. The Court has reviewed the Motion and is fully advised in the premises. It is thereupon CONSIDERED, ORDERED AND ADJUDGED that Defendant EDWARDS' Motion for Reconsideration is hereby denied. DONE AND ORDERED this _ day of January, 2011 at West Palm Beach, Palm Beach County, Florida. 8 /04% ) DAVID F. CROVIVRe. "<$ 4

unsel for Plaint; In related Cases Nos. 08-80069, 08-80119, 08- Paul G. Cassell, Esq. 80232, 08-80380, 08-80381, 08-80993, 08- Pro Rae Vice 80994 Jack Alan Goldberger, Esq. Counsel for Defendant Jetty Estein Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. 'a Law Firm P.A. Counsel for Plaintiff in Rela

381, 08-80993, 08- Pro Rae Vice 80994 Jack Alan Goldberger, Esq. Counsel for Defendant Jetty Estein Co-cou

ED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and Appeal of Portions of the Magistrate's Order (DE 462) pursuant to Rule 60, Fed.R.Civ.P. Rule 4, Rule 4(c) and