Epstein Secrets

ct Court, Southern District of Florida Jack Alan Goldberger, Esq. igoldberger(W.agwpa.com Michael R. Tein,

Entered on FLSD Docket 10/31/2008 Page 11 of 11 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. igoldberger(W.agwpa.com Michael R. Tein, Esq. [email protected] Robert D. Critton, Esq. [email protected] Michael Pike, Esq. moike@b

States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401. Please understand

ort of their claims in Counts I and Ill. According to Defendant, the pleadings in this case do not satisfy "the standard of pleading" established in Bell Atlantic Corp.'. Twombly 127 S.Ct. 1955 (2007). In making this argument, Defendant would extend Twombly well beyond its intended scope. Twombly was an antitrust c

7 LEAD ATTORNEY ATTORNEY TO BE NOTICED Defendant Jeffrey Epstein represented by Jeffrey Epstein 9 East 71st Street New York, NY 10021 PRO SE Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach , FL 33401-5012 Fax: 835-8691 Email: ATTORNEY TO BE

Order) (Horowitz, Adam) (Entered: 06/05/2008) 06/13/2008 1.0 NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of Jeffrey Epstein (Goldberger, Jack) (Entered: 06/13/2008) 06/13/2008 11 MOTION to Set Aside Default by Jeffrey Epstein. (Attachments: # I Affidavit https://ecf.flsd.uscourts.g

underlying elements of her claims. Supporting Memorandum of Law Standard on Rule 12(b)(6) Motion To Dismiss As established by the Supreme Court in Bell Atlantic Corp.'. Twombly 127 S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead EFTA00175793 Case 9:08-cv-8( 3-KAM Docume

Burman Critton Luttier & Coleman 515 N Flagler Drive Suite 400 s P Im Beach , FL 33401-2918 Fax: 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 Email: ATTORNEY TO BE NOTICED Michae

ault Order)(Horowitz, Adam) (Entered: 05/29/2008) 06/13/2008 6 NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of Jeffrey Epstein (Goldberger, Jack) (Entered: 06/13/2008) 06/13/2008 7 RESPONSE to Motion re 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant Jane Doe No. 3

underlying elements of her claims. SupportIna Memorandum of Law Standard on Rule 12(b)(6) Motion To Dismiss As established by the Supreme Court in Bell Atlantic Corp.'. Twomblv 127 S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead "enough facts to state a claim to relief that

35 CM/ECF - Live Database - fisd Page 2 of 14 ATTORNEY TO BE NOTICED Defendant Jeffrey Epstein AJWCUS United States of America represented by Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach , FL 33401-5012 Email: ATTORNEY TO BE NOTICED Michae

d Order) (Horowitz, Adam) (Entered: 06/05/2008) 06/13/2008 I NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of Jeffrey Epstein (Goldberger, Jack) (Entered: 06/13/2008) 06/13/2008 2 MOTION to Set Aside Clerk's Default by Jeffrey Epstein. (Attachments: # I Affidavit of Richard Bamett)(G

in the light most favorable to the plaintiff. . DeKalb County Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006). Significantly, the Supreme Court in Bell Atlantic Corp.'. Twombly abrogated the often cited observation that "a complaint should not be dismissed for failure to state a claim unless it appears beyond doub

ddress) LEAD ATTORNEY ATTORNEY TO BE NOTICED Stuart S. Mermelstein (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED represented by Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 , FL 33401-5012 Fax: 8 Email: ATTORNEY TO BE NOTICED Martin G. Wein

xhibit B)(Horowitz, Adam) (Entered: 06/11/2008) 06/13/2008 IQ NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of Jeffrey Epstein (Goldberger, Jack) (Entered: 06/13/2008) 06/13/2008 11 RESPONSE to Motion re 9 Plaintiffs MOTION to Compel Clerk to Enter Default Against Defendant, or Altern

underlying elements of her claims. Supporting Memorandum of Law Standard on Rule 12(b)(6) Motion To Dismiss As established by the Supreme Court in Bell Atlantic Corp.'. Twombly, 127 S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead EFTA00175634 Case 9:08-cv-L .19-KAM Docur