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[email protected] Counsel for Plaintiffs In related Cases Nos. 0840069, 08-80119, 08- 80232, 08-80380, 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. AUerbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 j
for copying, including certain witness interviews. Egg Exhibit "H" Affidavit of Jack Goldberger. Accordingly, the information hand selected by Mr. Goldberger falls under the work-product doctrine as production of same would reveal Mr. Goldberger's mental impressions, thought processes and strategy relati
. R. Crim, P. 11(f) and 410: "to encourage non- litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d 1072, 1074 (11th Cir. 1976). ee ug. Stockman v. Oakcrest Dental Center P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose underlying Rule 408 . . . is the promotion of the public policy favor
orowitz(alsexabuseattorney.com Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-801 J9, 08- 80232, 08-8038~ 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691
for copying, including certain witness interviews. See Exhibit "H" Affidavit of Jack Goldberger. Accordingly, the information hand selected by Mr. Goldberger falls under the work-product doctrine as production of same would reveal Mr. Goldberger's mental impressions, thought processes and strategy relati
Crim, P. 11 (f) and 410: "to encourage non- litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d 1072, 1074 (11th Cir. 1976). See, Lls·, Stockman v. Oakcrest Dental Center, P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose underlying Rule 408 ... is the promotion of the public policy favori
unsel for Plaint; In related Cases Nos. 08-80069, 08-80119, 08- Paul G. Cassell, Esq. 80232, 08-80380, 08-80381, 08-80993, 08- Pro Rae Vice 80994 Jack Alan Goldberger, Esq. Counsel for Defendant Jetty Estein Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. 'a Law Firm P.A. Counsel for Plaintiff in Rela
381, 08-80993, 08- Pro Rae Vice 80994 Jack Alan Goldberger, Esq. Counsel for Defendant Jetty Estein Co-cou
lying Rules 11(f) and 410: "to encourage non-litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d ion, 1074 (11th Cir. 1976). Zes, zgr. Stockman v. Oakcrest Dental Center, P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose underlying Rule 408 . . . is the promotion of the public policy favo
. Attorney General’s Office in Florida says that it is against policy to confirm or deny the existence of an investigation. Jeffrey Epstein’s lawyer, Jack Goldberger, says he has no knowledge of an ongoing probe, and he told The Daily Beast, "Jeffrey Epstein has fully complied with all state and federal requiremen
an investigation. Jeffrey Epstein’s lawyer, Jack Goldberger, says he has no knowledge of an ongoing probe, an
t 27, 2010 from Michelle Stockman of Agence France Presse. (Exhibit E attached). Agence France Presse is a newswire service with a world- wide reach. Stockman wanted to meet with Plaintiff Brunel to arrange a model shoot with MC2. However, due to the adverse publicity surrounding Plaintiffs as a result of E
Attorney General's Office in Florida says that it is against policy to confirm or deny the existence of an investigation. Jeffrey Epstein's lawyer, Jack Goldberger. says he has no knowledge of an ongoing probe, and he told The Daily Beast. "Jeffrey Epstein has fully complied with all state and federal requirem
an investigation. Jeffrey Epstein's lawyer, Jack Goldberger. says he has no knowledge of an ongoing probe, a
27, 2010 from Michelle Stockman of Agence France Presse. (Exhibit E attached). Agence France Presse is a newswire service with a world- wide reach. Stockman wanted to meet with Plaintiff Brunel to arrange a model shoot with MC2. However, due to the adverse publicity surrounding Plaintiffs as a result of
Entities connected to both Jack Goldberger and Stockman

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONLeon Black
PERSONScott Rothstein
PERSON
George W. Bush
PERSONMichael J. Pike
PERSONJack Scarola
PERSON
Alexander Acosta
PERSON
Adam D. Horowitz
PERSONRobert C. Josefsberg
PERSONRoy Black
PERSON
United States
LOCATIONMaria Farmer
PERSON
Department of Justice
ORGANIZATION
Jay Lefkowitz
PERSONKatherine W. Ezell
PERSON