Epstein Secrets

T Scott J. Link, Esq. Link & Rockenbach, P.A. 1555 Palm Beach Lakes Boulevard Suite 301 West P 33401 Pho Fax: Attorneys for Jeffrey Epstein Jack A. Goldberger, Esquire Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phone: Fax: Attorneys for Jeffrey Eps

Pho Fax: Attorneys for Jeffrey Epstein Jack A. Goldberger, Esquire Atterbury Goldberger & Weiss, P.A. 250

e four abandoned counts in an inoperative pleading that was no longer part of the record was now a nullity. 6. On August 21, 2011, Epstein filed a Second Amended Complaint against Defendant Rothstein. In his Second Amended Complaint, which supersedes the Amended Complaint, Epstein abandoned his Abuse of Process claim

F on thi day of April, 2009: Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. Counsel for Plaintiff Jane Doe #1 Jack Alan Goldberger Atterbury Goldberger & Weiss. P.A. Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By: ROBERT D. RITTON, JR., ESQ. Florida Bar o. 224

.A. Counsel for Plaintiff Jane Doe #1 Jack Alan Goldberger Atterbury Goldberger & Weiss. P.A. Co-Counsel f

s ability to earn a living and be self-supporting has not only a financial component, but also an emotional/psychological/mental component. In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional Distress," and

Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Co-Counsel for Defendant Jeffrey Epstei

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

nfidentiality of the information obtained through discovery. The evidence sought is relevant based on the facts and theories of this action. In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional Distress," and

akes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, ■., 250 Aus

2th day of December, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, ■., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Office

lving your misconduct with minor females. Answer: If there is a contract for legal services relating to the damages claimed by Mr. Epstein in his Second Amended Complaint, it will be produced. Plaintiff objects to producing any and all other contracts for legal services in the defense of criminal charges or other civi

otion for Protective Order Relating to his Deposition and in Support of Edwards' Motion to Compel and hnposc Sanctions Page IS of IS COUNSEL LIST Jack A. Goldberger, Esquire Attirbury, Goldberger & Weiss, P.A. 25 Australian Avenue South, Suite 1400 Wet Palm Beach, FL 33401 Ph e: (561) 659-8300 : (561) 835-86

c Sanctions Page IS of IS COUNSEL LIST Jack A. Goldberger, Esquire Attirbury, Goldberger & Weiss, P.A. 25

and prosecute against El) ARDS and the pending, closely related counterclaims. FACTUAL BACKGROUND Plaintiff/Counterdefendant, EPSTEIN has filed a Second Amended Complaint against ED ARDS. The complaint challenges EDWARDS' professionalism as an attorney rep enting girls who had been sexually abused. In particular,

s Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, 250 Australian A

e like this one, "a case where the case had never been at issue." Serban, 148 So. 3d at 1291(quoting Labor Ready). Furthermore, Epstein's operative Second Amended Complaint, which had neither been answered nor defaulted, contained a "brand-new" count alleged in response to the trial court's order dismissing the prior a