Epstein Secrets

[email protected] FOR THE Respondent Jack Alan Goldberger [LEAD ATTORNEY:PRO HAC VIC] Atterbury, Goldberge

& Bird, LLP(NYC) 90 Park Avenue New York, NY, USA 10016 (212) 210-9400 Fax: (212) 210-9444 Email:[email protected] FOR THE Respondent Jack Alan Goldberger [LEAD ATTORNEY:PRO HAC VIC] Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, #1400 West Palm Beach, FL, USA 33401 (561)-659-8305

Y-0023149 EFTA_00 170863 EFTA01297312 Page 3 Giuffre V. Maxwell 1:15cv7433 PLAINTIFF ATTORNEY(S): Sigrid S. McCawley [ATTORNEY TO BE NOTICED) Boles, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL, USA 33301 954-356-0011 Fax: 954-356-0022 Email:Smccawley@bsfl

the date of the complaints by the parents was May 22 or May 23, 2008. It was the week that Mr. Epstein had hired new counsel there which was a Mr. Jack Goldberger from West Palm Beach. And Mr. Goldberger was scheduled, according to the incident report, to meet with the representatives of the State SOUTHERN D

May 22 or May 23, 2008. It was the week that Mr. Epstein had hired new counsel there which was a Mr. Jack Goldberger from West Palm Beach. And Mr. Goldberger was scheduled, according to the incident report, to meet with the representatives of the State SOUTHERN DISTRICT REPORTERS, P.C. EFTA00079790 1

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Mr. Boies? MR. BOIES: Yes, your Honor. THE COURT: Hold on one second. Mr. Boles, just wait until we finish with them. I take it that the answer is yes? MR. BOIES: Yes, your Honor. THE COURT: Go ahead. MR. : Your Honor, my

the date of the complaints by the parents was May 22 or May 23, 2008. It was the week that Mr. Epstein had hired new counsel there which was a Mr. Jack Goldberger from West Palm Beach. And Mr. Goldberger was scheduled, according to the incident report, to meet with the representatives of the State SOUTHERN D

May 22 or May 23, 2008. It was the week that Mr. Epstein had hired new counsel there which was a Mr. Jack Goldberger from West Palm Beach. And Mr. Goldberger was scheduled, according to the incident report, to meet with the representatives of the State SOUTHERN DISTRICT REPORTERS, P.C. EFTA00095432 1

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Mr. Boies? MR. BOIES: Yes, your Honor. THE COURT: Hold on one second. Mr. Boles, just wait until we finish with them. I take it that the answer is yes? MR. BOIES: Yes, your Honor. THE COURT: Go ahead. MR. : Your Honor, my

er burden if he were suing for defamation, he should be afforded more latitude in responding when others allegedly defame him. In Sullivan Justice Goldberg illuminated some of the concerns the Court was targeting, writing, "[T]he Constitution accords citizens and press an unconditional freedom to crit

claim the statement he attributed to Boies that claims were "wrong ... simply wrong." (Comp. at 17(c)). Although the Complaint does not state that Boles is the lawyer who made the statement, it concedes that the statement was made and that the statement was used to sup r ii ershowitz's claim that D