Epstein Secrets

ritton, Jr., 303 Banyan Boulevard, Suite 400, West Palm Beach, FL 33401 Gary M. Farmer, Jr 425 N. Andrews Ave., Suite 2, Fort Lauderdale, FL 33301 Jack Alan Goldberger, Esq., 250 Australian Avenue South, Suite 1400, WPB, FL 33401 EFTA00728450 EXHIBIT 2 EFTA00728451 SUPREME COURT OF THE STATE OF NEW YORK COUNT

e., Suite 2, Fort Lauderdale, FL 33301 Jack Alan Goldberger, Esq., 250 Australian Avenue South, Suite 1400, W

molestation from discovery. It is for this reason, among others, that production of the tape on which he speaks about his molestation is critical. A. Epstein's Vicious Attacks on the Girls 5. Epstein's battery of attorneys have taken the girls' depositions, in which they have asked numerous questions sugg

egan approaching the State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by t

f attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.

ng records are either work product or attorney-client communications that need not be produced. This assertion fails both procedurally and legally. A. Epstein's Claim of Privilege Is Waived by His Failure to Carry His Burden of Proving Its Applicability. Procedurally, the person asserting the privilege bear

egan approaching the State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by t

f attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.

ng records are either work product or attorney-client communications that need not be produced. This assertion fails both procedurally and legally. A. Epstein's Claim of Privilege Is Waived by His Failure to Carry His Burden of Proving Its Applicability. Procedurally, the person asserting the privilege bear