Epstein Secrets

ERVICE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. Mail, postage prepaid, this 2¢ day of June, 2009 to hick A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm B

F SERVICE CI HEREBY CERTIFY that a true and correct cop.), of the foregoing has been served I U.S. Mad and Facsmile this ( klay of May, 2009 to: Jack Alan Goldberger, Esq., ... . ---- Aiterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401. EFTA00180794 I j ROTHSTBIN RO

, & COLEMAN, 515 N. Fiagler Dr. Suite 400, West Palm Beach, Florida 33401. this 11 day of June, 2009. BURMAN, CRITTON, LUTTIER & COLEMAN ATTERBURY, GOLDBERGER & 515 N. Fiagler Dr. Suite 400 WEISS, P.A. West Palm Beach, Florida 33401 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 -c

ld a stay not be 769 So.2d 389, 391 n.4 (Fla. 3d DCA 1999). Defendants fail to adequately ad completely ignores the likelihood likelihood that the Fourth District would reverse for sealing the NPA were never followed. As to likelihood of harm, the only reference Defendan paragraph 3 of his motion. Here, Defe

IFICATE OF SERVICE Y CERTIFY that a true and correct copy of the foregoing has been served via U.S. Mail and Facsmile this I Pday of May, 2009 to: Jack Man Goldberger, Esq., ---- Ahterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401. 2 EFTA00231293 ROMSTETtlitOSENFELDT

Beach, FL 401 F By: Robert D. Cri on, Jr. Florida Bar 24162 Michael J. Pike Florida Bar #617296 Counsel for Defendant Jeffrey Epstein) and Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beac FL 33401-5012 Fax: Counsel for Defendant Jeffrey

..... ....... EXHIBIT PORTER PHYLLIS A. DAAES, I EFTA00231300 „ . • 38 1 on that, Your Honor? 2 THE COURT: It is 3 recorded. 4 MR. GOLDBERGER: That's fine. 5 THE COURT: Defendant needs to 6 approach as well. 7 (Whereupon, there was a conference at 8 the bench.) 9 MR. GOLDBERGER; T

ately ad s these fa rs in their motion. In fact, Defendant completely ignores the likelihood Likely this is because there is no likelihood that the Fourth District would reverse ling since the proper procedures for sealing the NPA were never followed. As to likelihood of harm, the only reference Defendan to

JA ET AL. SERVICE LIST Jack Scarola, Esq. Searcy Denney Scarola et al. 16 EFTA00808220 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

t was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his malicious prosecution action, during which time the Fourth District issued Fischer v. Debrincat, 169 So. 3d 1204 (Fla. 4th DCA 2015), holding that the litigation privilege did not apply to a malicious prosecution ac

rik, Esq. LAW OFFICES OF MARC S. NURIK 1 E. Broward Blvd., Ste. 700 Fort Lauderdale, FL 33301 i 54 715-58‘.1. Attorneys for Scott Rothstein 12 Jack Goldberger, Esq. ATTERBURY, GOLDBERGER & WEISS, P.A. 250 S. Australian Ave., Ste. 1400 West Palm Beach, FL 33401 561)659-8300 Attorneys for Jeffrey Epstei

5-58‘.1. Attorneys for Scott Rothstein 12 Jack Goldberger, Esq. ATTERBURY, GOLDBERGER & WEISS, P.A. 250

y to make an informed decision of acceptance or rejection. One aspect of Swartsel was disagreed with by the Supreme Court in Nichols. In Swartsel, the Fourth District held parties were required to specify all terms of a settlement (882 So.2d at 453). Then in Nichols, the Supreme Court held parties could summarize

, air. IS A No. 19 42 and are you familiar with the law firm that 20 was representing Mr. Epstein while you were involved? 21 A well, lack Goldberger and the Luttier firm, I 22 believe. 33 0 Bob Critton. 24 A Critton. 23 0 Dld you know Bob Critton? Palm Beach Reporting Service, Inc. 561

ve -- I 10 think I mot him during the Ep➢tein deposition. But II that might have bean the first time I mot him. 11 0 Now about Kr. Goldberger, Jack Goldberger? 13 A Probably the first time I mat him, too. 14 0 Did you do any research on Mr. Crltton or 39 Mr. Goldberger? 26 A No. I didn't do resea

So I served on the 12 Fourth District and served with a panel of judges 13 and heard quite a number of cafes and wrote several 14 decisions for the Fourth District. Q The jury may not be familiar with the 14 procedure, but when the appellate court reviews 17 decision➢ that are rendered and jury trial re➢ul

JA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 25 EFTA00799363 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . • Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward B

h, FL 33409 Jack Goldber er, Es . • Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 14

t was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his malicious prosecution action, during which time the Fourth District issued Fischer v. Debrincat, 169 So. 3d 1204 (Fla. 4th DCA 2015), holding that the litigation privilege did not apply to a malicious prosecution act

DAD COLEMAN, ESQUIRE For Jeffrey Epstein: ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 By JACK A. GOLDBERGER, ESQUIRE For Jeffrey Epstein: DARREN K. INDYKE, PLLC 575 Lexington Avenue New York, NY 10022 By DARREN K. INDYKE, ESQUIRE Palm Beach Reporting

and read for the better part of five or six hours. I tried to highlight as many of the provisions as I thought were appropriate as possible. Mr. Goldberger, I see that you are here. I have not yet seen a motion to stay. MR. GOLDBERGER: It's here, Your Honor. It's ready to go. I am going to file it to

cted the summary judgment on probable cause and bona fide termination. We filed an appeal. That case was briefed. And prior to the oral argument, the Fourth District rejected the Wolfe case. Now, what happened in the briefing in our case is our initial brief addressed solely litigation privilege, because that

ive, Suite 400 each, FL 401 By: Robert D. Cri Florida Bar Michael J. Pike Florida Bart_ Counsel for Defendant Jeffrey Epstein) and on, Jr. Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 W Pa a FL 33401-5012 Fax: Counsel for Defendant Jeffrey Epst

_ ...... _ PHYLLIS A. DAMES, PORTER EFTA00232420 e ri 1 on that, Your Honor? 2 THE COURT: It is Ding—t.o—las ) 38 3 recorded. 4 MR. GOLDBERGER: That's fine. 5 THE COURT: Defendant needs to 6 approach as well. 7 (Whereupon, there was a conference at 8 the bench.) 9 MR. GOLDBERGER: Th

equately ad•` s fa ;•rs in their motion. In fact, Defendant completely ignores the likelihood Likely this is because there is no likelihood that the Fourth District would reverse ling since the proper procedures for sealing the NPA were never followed. As to likelihood of harm, the only reference Defendan to