Epstein Secrets

here from New Jersey -- that this case was going to be heard today. The lawyers had filed the motion to quash, Martin Weinberg and Jack Goldberger. Jack Goldberger is a Florida lawyer. He's in Palm Beach right now. Martin is in Boston. Martin, I think he sent an email to chambers. And what he told me before I

ed the motion to quash, Martin Weinberg and Jack Goldberger. Jack Goldberger is a Florida lawyer. He's in Pa

22 23 24 25 problem. Well, no, it isn't. No, it isn't. Okay. So let's do 675. MS. MENNINGER: Your Honor, I will say that it is my reading of Rule 412 that any hearing that is based upon in part Rule 412 is supposed to be conducted in a in camera setting. MS. SCHULTZ: Counsel for Ms. has no objec

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

conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu

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

conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu

3 Entered on FLSD Docket 05/06/2009 Page 9 of 9 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] /s/ Adam D. Horowitz -9- EFTA00222170

ct Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton,

urt "must impose certain restriction on discovery to preclude inquiry into areas which will clearly fail to satisfy the balancing test" set forth in Rule 412. See Barta I. City and County of Honolulu, 169 F.R.D. at 135. In Barta, the Court confronted this issue in the context of a discovery motion in a c

m New Jersey -- that 15 this case was going to be heard today. The lawyers had filed 16 the motion to quash, Martin Weinberg and Jack Goldberger. Jack 17 Goldberger is a Florida lawyer. He's in Palm Beach right now. 18 Martin is in Boston. Martin, I think he sent an email to 19 chambers. And what he told me b

16 the motion to quash, Martin Weinberg and Jack Goldberger. Jack 17 Goldberger is a Florida lawyer. He's i

same 2 problem. Well, no, it isn't. No, it isn't. 3 Okay. So let's do 675. 4 MS. MENNINGER: Your Honor, I will say that it is my 5 reading of Rule 412 that any hearing that is based upon in part 6 Rule 412 is supposed to be conducted in a in camera setting. 7 MS. SCHULTZ: Counsel for Ms. has no

ated Cases Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

ch Gardens, FL 33410 Fax: Counsel for Plaintiff in Related Case No. 08- 08804 Counsel for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 Beach, FL 33401-5012 Counsel for Defendant Jeffrey Epstein EFTA

l conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu