Epstein Secrets

JEFFREY EPSTEIN, Defendant. MOTION FOR PROTECTIVE ORDER AS TO THE DEPOSITION OF Third-Party Witness, by and through her undersigned attorney, Jack A. Goldberger, and pursuant to Rule 1.280(c), Florida Rules of Civil Procedure, moves for a Protective Order to reschedule her deposition currently set for Monday

by and through her undersigned attorney, Jack A. Goldberger, and pursuant to Rule 1.280(c), Florida Rules of

oing was sent by fax and U.S. Mail to the following addressees on this 13th day of October, 2009: Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Lehrman, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 954-524-2820 Phone 954-524-2822 Fax Counsel for Plaintiff. & EW Jay Howell, Esq. Jay

ay of July, 2010: Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL Paul G. Cassell, Esq. Pro Hoc Vice o-counse or at Jack Alan Goldberger, Esq. Atterbtuy Goldberger & Weiss, P.A. By: la Robert P. Critton. Jr. ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] M

ll, Esq. Pro Hoc Vice o-counse or at Jack Alan Goldberger, Esq. Atterbtuy Goldberger & Weiss, P.A. By: l

Obtained By Jane Doe's attorneys during discovery, and each state: I. In July 2010, the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos and Lehrman, PL. (the "Law Finn"), Paul G. Cassell, Esq. and Jay Howell, Esq. ("Counsel") received through discovery certain correspondence and documents (including

Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax cassellp®law.utah.edn 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 561-835-8691 Fax j

law.utah.edn Co-counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

Obtained By Jane Doe's attorneys during discovery, and each state: I. In July 2010, the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos and Lehrman, PL. (the "Law Finn"), Paul G. Cassell, Esq. and Jay Howell, Esq. ("Counsel") received through discovery certain correspondence and documents (including

in the manna specified via transmission of Notices of Electronic Filing generated by CM/ECF on this 19th day of July, 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbu Goldber er & Weiss, P.A. & Lehrman, PL Paul G. Cassell, Esq. Pro Hoc Vice By: Is! Rober

ay of July, 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos

Obtained By Jane Doe's attorneys during discovery, and each state: I. In July 2010, the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos and Lehrman, PL. (the "Law Finn"), Paul G. Cassell, Esq. and Jay Howell, Esq. ("Counsel") received through discovery certain correspondence and documents (including