Epstein Secrets

the undersigned and his criminal attorney, Jack Goldberger, Esq., and both were present for the above depos

r. Epstein was in attendance for said deposition. 2. Mr. Epstein is represented in this action by both the undersigned and his criminal attorney, Jack Goldberger, Esq., and both were present for the above deposition. 3. Spencer Kuvin, counsel for Plaintiff, E., was the attorney scheduled to take Mr. Epstei

So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), citing, Hickman v. Taylor, 329 U.S. 495, 501, 507 (1947). 21. Next, the right to go to court to resolve disputes is a fundamental right. D.R. Lakes. Inc. v. Brandsmart U.S

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

So.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), citing, Hickman v. Taylor, 329 U.S. 495, 501, 507 (1947). 14. Next, the right to go to court to resolve disputes is a fundamental right. D.R. Lakes, Inc. v. Brandsmart U.S

much broader fashion," weighing the veracity of witnesses and how they may fare under defense attorneys' questioning, he said. Epstein's attorney, Jack Goldberger, said his client committed no crimes. "The reports and statements in question refer to false accusations that were not charged because the Palm Be

uestion refer to false accusations that were not charged because the Palm Beach County state attorney questioned the credibility of the witnesses," Goldberger said. A county grand jury "found the allegations wholly unsubstantiated and not credible," and that's why his client was not charged with sexual a

oenas violate the work-product doctrine, as well as Mr. Epstein's Fifth Amendment right to due process and his Sixth Amendment right to counsel. In Hickman v. Taylor, 329 U.S. 495, 510-11 (1947), the Supreme Court recognized the modern work- product doctrine, holding that: [lin performing his various duties, how

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.'

ain hidden in an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman v. Taylor, 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation," In re

2265 File folder entitled "JEGE & Hyperion from Goldberger OLY-46 & OLY-47" containing documents received i

that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an