Epstein Secrets

Y, GOLDBERGER & WEISS 17 Co-Counsel for Defendarus One Clearbke Court 18 Suite 1400 West Palm Beach. Florida 33401 19 Tel: (561)659.8300 BY: JACK A. GOLDBERGER. ESQ. 20 21 22 23 24 25 ALSO PRESENT: JESSICA CADWELL JOE ROVNER. Videographer (U.S. Legal) 3 1 The videotaped deposition of — 2 in the

er your question, I must invoke my Fifth and Sixth Amendment privileges and refuse to answer your questions. Q What is your current address? MR. GOLDBERGER: There is going to be a continued, obviously, you anticipate I'm sure, continued invocation of Fifth 2 (Pages 2 to 5) U.S. Legal Support (561) 8

Australian Avenue South West Palm Beach. Oxide 33901 8 9 10 ATIENTION: JACK GOLDBERGER. ESQ. In Re: DOE EPSTEIN Depositica at _- 11 12 One Mt Goldberger. 13 Since counsel have agreed that you nay have the witness read and sip your copy of the 19 deposition, far your conthoience, withal herewith

12 13 14 15 16 17 18 19 20 21 22 23 24 25 in either 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Did you, in fact, call A.G. to come to Jeffrey Epstein's home and give him a massage in a sexual nature in 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Dld you

for a massage of a sexual nature? MR. YAREMA: Object to the Iona. A Fifth. Q Did Jeffrey Epstein tell you it was his intent during the course of A.G.'s visit to his home to persuade, induce or entice her to engage in sexual activity? MR. YAREMA: Object to the form. A Fifth. Q Didn't Jeffrey Ep

RDC Motion for Additional Time to Complete Examination (AC); prepare additional 0.90 hr $450.00 Affidavit for Caddy 03/10/2009 JMB E-mail to Jack Goldberger, Esq. 0.10 hr $50.00 03/10/2009 RDC Review CMA Motion plus suggestions; conference with JMB and Rita re: thoughts 0.80 hr $400.00 03/10/2009

claim analysis, etc. Conference with client and Goldberger Conference with RHB; prepare Motions for Extensi

yk regarding RICO 0.30 hr $90.00 03/03/2009 JMB Conference with Robert Critton a40 iv $200.00 03/03/2009 RDC Attend two hearings i M and A.G.); conference with Sid 1.60 hr $800.00 03/03/2009 RDC Memo to all 0.40 hr $200.00 03/0312009 RDC Conference with JMB and Rita re: new Compla

the U.S. Attorney's Office sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, reflectin

r cases were still under investigation. Tr. July I I, 2008 at 4-6, 18-19, 22-23. 42. On June 30, 2008, the U.S. Attorney's Office sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, reflecting continuing efforts to keep the NM secret:' 19 EFTA00229935 7: Case 9:08-cv-80736-KAM Document

sonable opportunity for further investigation or discovery. Fed. R. Civ. P. I1(b). Rule 1 1 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu

the U.S. Attorney's Office sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, reflectin

ir cases were still under investigation. Tr. July 11, 2008 at 4-6, 18-19, 22-23. 42. On June 30, 2008, the U.S. Attorney's Office sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, reflecting continuing efforts to keep the NM secret 19 08-80736-CV-MARRA 000689 EFTA00230513 7: Case 9:

reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu

h acromegalic from normal pulsatile growth hormone release. J. Clin. Invest. 94:1277-1288. Hausdorff, J.M., Cudkowicz, M.E., Firtion, R., Wei, J.Y., Goldberger, A.L. (1998) Gait variability and basal gangia disorders: stride-to-stride variations in gait cycle timing in Parkinson’s and Huntington’s disease.

auser. Boston Adler, R.L., Goodwyn, L.W., Weiss, B. (1977) Equivalence of topological Markov shifts. Isreal J. Math. 27:49-63 Adler, R.L., Konheim, A.G., McAndrew, M.H. (1964) Topological entropy. Trans. Amer. Math. Soc. 114:309-319 Adler, R.L., Marcus, B. (1979) Topological entropy and equivalence o