Epstein Secrets

S TEIN, P.L. GUY A. LEWIS Fla. Bar No. 623740 [email protected] MICHAEL R. TEIN Fla. Bar No. 993522 ATTERBURY, GOLDBERGER & WEISS, P.A. By: Jack A. Goldberger Fla. Bar No. 262013 [email protected] Attorneys for Defendant Jeffrey Epstein 23 Lewis Trin 3059 Guam Avisyt,Sunt 340, Comm, Glow, /toes. 3

hes to ask an appropriate worded question with the proper foundation and predicate, I will certainly allow the client to answer the question. MR. GOLDBERGER: Why don't you just state attorney/client privilege and just be done with it? MR. LEOPOLD: I want the record to be clear. MR. TEIN: You want to

Doe is a citizen of Florida. (Am. Compl. ¶ 1.) 6 Jane Doe may, in fact, be a citizen of Georgia. not Florida, as she pled in her Amended Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D

ircuit Court Judge Copies forwarded to: Jack A. Goldberger, Esq. Counsel for the Defendant 250 Australian

s, West Palm Beach, Palm Beach County, Florida this day of July, 2008. „Ana gates EBORAH DALE PUCILLO Circuit Court Judge Copies forwarded to: Jack A. Goldberger, Esq. Counsel for the Defendant 250 Australian Avenue South, Ste. 1400 West Palm Beach, Florida 33401 Lanna Belohlavek, Esq. Assistant State Att

fendants claim that , who has described herself as Heidi Fleiss (the Hollywood madam),' has "nothing to do with the plaintiff's case against Mr. I See New York Post, Oct. 1, 2007 (reporting "Some of the girls, legal documents indicate, were recruited by I now 21, who described herself as `like Heidi Fleiss,' th

.pl?688131043345764-1.,_801 0-1 10/8/2008 EFTA00175521 CM/ECF - Live Pntabase - flsd Page 2 of 6 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach , FL 33401-5012 Fax: 835-8691 Email: LEAD ATTORNEY

LEAD ATTORNEY ATTORNEY TO BE NOTICED Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australi

Defendants claim that who has described herself as Heidi Fleiss (the Hollywood madam),' has "nothing to do with the plaintiff's case against Mr. ' See New York Post Oct. 12007 (reporting "Some of the girls, legal documents indicate, were recruited by now 21, who described herself as `like Heidi Fleiss,' the no

e the list to the Federal Grand Jury investigation and thus to the non- disclosure provisions of Fed. R. Crim. P. 6(e). On July 8, 2008, you wrote to Jack A. Goldberger, Esq., and informed him that on June 30, 2008, "the United States Attorney's Office provided [him] with a list of thirty-one individuals 'whom it wa

me in an Indictment as victims of an enumerated offense by Mr. Epstein.'" (emphasis added). On July 9, 2008, you wrote in a follow-up letter to Mr. Goldberger that "the U.S. Attorney's modification of the 2255 portion of the Agreement now limits our victim list to those persons whom the United States was

Doe is a citizen of Florida. (Am. Compl. ¶ 1.) 6 Jane Doc may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended Complaint. See New York Post, Jul. I, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D

Mr. Herman in the presence of IMO" 2 A. None. 3 Q. What discussions did you have in the 4 presence of her aunt? 5 A. Of my aunt? 6 MR. GOLDBERGER: It's the witness's aunt. 7 BY MR. TEIN: 8 Q. Oh, of your aunt. 9 A. The only one that we've ever discussed or 10 ever had. 11 Q. And so

Doe is a citizen of Florida. (Am, Compl. ¶ 1.) 6 'Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D