Epstein Secrets

lm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424 [email protected] johasearcylaw.com Co-Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691

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

ally identified in subsection (a) of the statute. Plaintiff in her response, p. 10, agrees that she has failed to sufficiently allege the predicate act(s) required by §2255. Defendant has no objection to Plaintiff attempting to amend, but Plaintiff should be required to plead a single cause of action

M/ECF on this day of March , 2009: Richard Horace Willits, Esq. Richard H Willits P A tom* Lake Worth, FL 33461 Counsel for Plaintiff C.M.A. Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss P.A. West Palm Beach, FL 33401-5012 ounse or a en an s Jeffrey Epstein and Sarah Kellen Jack Scarola, Esq.

FL 33461 Counsel for Plaintiff C.M.A. Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss P.A. West Pa

2255 claim to go forward without specifying the statutory predicate act and factual allegations pertaining to a violation of the requisite predicate act(s). Accordingly, under EFTA00201199 Case 9:08-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 11 of 21 C.M.A. v. Epstein, et al.

S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 401-5012 Co-Counsel for Defendant Jeffrey Epstein Respec By: D. CR

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

tify that Plaintiff was paid by others for similar sexual acts she claims Mr. Epstein forced upon her or that she willingly participated in certain act(s) that would negate or lessen her damages. This goes directly to Plaintiffs damage claim. 7. Likewise, subpoenas must be issued to third-party trea

Acosta, DEF: Kenneth Starr, Jay Lefkowitz, Lilly Sanchez). EFTA01718570 9/12/2007--Meeting (US: and , DEF: Jay Lefkowitz, Gerald Lefcourt and Jack Goldberger, STATE OF FLORIDA: Barry Krisher and Lanna Belohlavek). 9/18/2007--Rescheduled date for computer hearing.(Hearing initially set for 9/13/2007). 9

7. cc: The Honorable Sandra McSorley AITEREDRY, GOLDBERGER eb WEISS, P.A. Beech, Flori 33401 JA A LDBER

y precludes the initiation or continuation of a federal prosecution, following a prior state or federal prosecution based on substantially the same act(s) or transaction(s) unless three substantive prerequisites are satisfied: first, the matter must involve a substantial federal interest; second, th

arey had on June 1, 2006, with ASA regarding a meeting earlier that day between representatives of the State Attorney's Office and defense attorney Jack Goldberger (Police Report at 87). Omitted are the facts of the meeting (Police Report at 87): In addition to the presence of other defense counsel, there was i

tate Attorney's Office and defense attorney Jack Goldberger (Police Report at 87). Omitted are the facts of t

iscretion by appropriate officers of the Department of Justice in determining whether to bring a federal prosecution based on substantially the same act(s) or transactions involved in a prior state or federal proceeding." The purpose of the policy "is to vindicate substantial federal interests through

et 06/05/2009 Page 4 of 4 COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 25

nhart Shipley, P.A. 2139 Palm Beach Lakes Boulevard st Palm Beach, FL 33409 Fax: jsxesearcvlaw.com jphesearcylaw.com Co-Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 net Counsel for Defendants Jeffr

ally identified in subsection (a) of the statute. Plaintiff in her response, p. 10, agrees that she has failed to sufficiently allege the predicate act(s) required by §2255. Defendant has no objection to Plaintiff attempting to amend, but Plaintiff should be required to plead a single cause of action

Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 F isidrogarcia(a:bellsouth.net Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 ch, FL 33401-5012 Fax jaqesaabellsouth.net Co-Counsel for Defe

a:bellsouth.net Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

tify that Plaintiff was paid by others for similar sexual acts she claims Mr. Epstein forced upon her or that she willingly participated in certain act(s) that would negate or lessen her damages. This goes directly to Plaintiff's damage claim. 7. Likewise, subpoenas must be issued to third-party tre

tective had on June 1, 2006, with regarding a meeting earlier that day between representatives of the State Attorney's Office and defense attorney Jack Goldberger (Police Report at 87). Omitted are the facts of the meeting (Police Report at 87): In addition to the presence of other defense counsel, there was i

tate Attorney's Office and defense attorney Jack Goldberger (Police Report at 87). Omitted are the facts of t

iscretion by appropriate officers of the Department of Justice in determining whether to bring a federal prosecution based on substantially the same act(s) or transactions involved in a prior state or federal proceeding." The purpose of the policy "is to vindicate substantial federal interests through

those words have real meaning by providing a telling example of an inadequate State process: "a state prosecution for assault and battery in a Mr. Goldberger. In short, it is hard to imagine how the recusal of an assistant to the lead prosecutor could have resulted in any advantage to Mr. Epstein; more to

Leflcowitz attaching draft Deferred Prosecution Agreement, Exhibit 32. 17 While federal prosecutors once suggested that Mr. Epstein's retention of Jack Goldberger was intended to trigger the recusal of assistant prosecutor Dahlia Weiss and thereby influence the outcome of the State prosecution, that assertion

to protect persons charged with criminal conduct from the burdens associated with multiple prosecutions and punishments for substantially the same act(s) or transaction(s)." Id. To that end, Petite "establishes guidelines for the exercise of discretion by appropriate officers of the Department of Jus

33401 this 7* day of December. 2007. ATIERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South Suite

y precludes the initiation or continuation of a federal prosecution, following a prior state or federal prosecution based on substantially the same act(s) or transaction(s) unless three substantive prerequisites are satisfied: first, the matter must involve a substantial federal interest; second, th