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

Page 9 of 11 if the plaintiff has a substantial privacy interest that outweighs the presumption of openness in judicial proceedings. Id., citing, Doe v. Frank, 951 F.2d 320, 323 (11th Cir. 1992)(requiring complaint to include the names of the parties serves more than administrative convenience, it protects

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

6 of 11 decide if the plaintiff has a substantial privacy interest that outweighs the presumption of openness in judicial proceedings. Id., citing, Doe v. Frank, 951 F.2d 320, 323 (11" Cir. 1992)(requiring complaint to include the names of the parties serves more than administrative convenience, it protects

Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 F isidrogarcia(a:bellsouth.net Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 ch, FL 33401-5012 Fax jaqesaabellsouth.net Co-Counsel for Defe

a:bellsouth.net Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

bstantial privacy interests JANE DOE has must outweigh the customary and constitutionally embedded presumption of openness to judicial proceedings. Doe v. Frank, 951 F.2d at 323; Doe v. Berostron, 2009 WL 528623 (C.A.9(Or.))(denying request to proceed anonymously in civil action by Plaintiff where Plaintiff