Epstein Secrets

[email protected] Counsel for Plaintiffs In related Cases Nos. 0840069, 08-80119, 08- 80232, 08-80380, 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. AUerbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 j

for copying, including certain witness interviews. Egg Exhibit "H" Affidavit of Jack Goldberger. Accordingly, the information hand selected by Mr. Goldberger falls under the work-product doctrine as production of same would reveal Mr. Goldberger's mental impressions, thought processes and strategy relati

al as that information is within the penumbra of the protections of Federal Rules of Evidence 408 and 410. Moreover, despite Plaintiffs contention, Federal Rule of Evidence 410 is applicable because negotiations did not end with a federal plea. Furthermore, Federal Rule of Evidence 408 is applicable given that 18 U.S.C. 22

. Attorney General’s Office in Florida says that it is against policy to confirm or deny the existence of an investigation. Jeffrey Epstein’s lawyer, Jack Goldberger, says he has no knowledge of an ongoing probe, and he told The Daily Beast, "Jeffrey Epstein has fully complied with all state and federal requiremen

an investigation. Jeffrey Epstein’s lawyer, Jack Goldberger, says he has no knowledge of an ongoing probe, an

r discovery of the correspondence between the U.S. and Epstein’s attorneys during the plea negotiations. Epstein’s attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations, barring release of the correspondence. They also argued that the

Attorney General's Office in Florida says that it is against policy to confirm or deny the existence of an investigation. Jeffrey Epstein's lawyer, Jack Goldberger. says he has no knowledge of an ongoing probe, and he told The Daily Beast. "Jeffrey Epstein has fully complied with all state and federal requirem

an investigation. Jeffrey Epstein's lawyer, Jack Goldberger. says he has no knowledge of an ongoing probe, a

r discovery of the correspondence between the M. and Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure I I create a privilege for plea negotiations, barring release of the correspondence. They also argued that t

y Edwards and his client to attend and address the Court at sentencing if they so desired. 38. On June 30, 2008, AUSA Villafafla sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, a copy of which is attached hereto as Exhibit _.that-statedi-ti-Jaek-The FRI-Iles-reeeived--seveml-ettlis-re

cult peri- od of his life behind him. He is continuing his longstanding history of science philanthropy both here In South Florida and nationwide." Goldberger had blocked the unsealing by filing court papers asking that the documents stay scaled "to prevent a se- rious imminent threat to the fair, impartial

y of the correspondence between the United States are Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations blocking release of the correspondence. They also argued that the