Epstein Secrets

that's appropriate. Not that we're entitled to the documents, not that they don't have any objection, but merely that they preserve the evidence. Bairr it's going to take us some time to unravel whether, in fact — whether and if there was inappropriate conduct, who did it, what the effects may be,

I know you've got a million 4 people here. 5 THE COURT: Yes. 6 MR. KEENAN: Judge, on behalf of Mr. Edwards 7 who is here, Mr. Edwards and Mr. Critton can try to 8 work out the language on an order for the 9 preservation of evidence. I think that's where 10 we're at right now. 1 Mr. Edwards,

st is? MS. SHULLMAN: Deanna Shulman. THE COURT: S-H-U-L — MS. SHULLMAN: THE COURT: Ms. Shullman, good morning. Mr. Berger, good morning, And Mr. Barr, your client is E — MR. BERGER: E.W.. yes. THE COURT: Anybody else has? MR. EDWARDS: Brad Edwards on behalf of E.W. as well, Judge. Thanks. Page

et al. 250 Australian Ave. South, Suite 1400 4 West Palm Beach, FL 33401 5 On behalf of the Defendant 6 ROBERT CRITTON, JR., ESQUIRE Burman, Critton, et al. 7 515 N. Flagler Drive, Ste. 400 West Palm Beach, FL 33401.4349 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 On

e certain restriction on discovery to preclude inquiry into areas which will clearly fail to satisfy the balancing test" set forth in Rule 412. See Barra'. City and County of Honolulu, 169 F.R.D. at 135. 5 EFTA00222175 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 6 o

SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] /s/ Adam D. Horowitz 10 EFTA00222180

st is? MS. SHULLMAN: Deanna Shulman. THE COURT: S-H-U-L — MS. SHULLMAN: THE COURT: Ms. Shullman, good morning. Mr. Berger, good morning, And Mr. Barr, your client is E — MR. BERGER: E.W.. yes. THE COURT: Anybody else has? MR. EDWARDS: Brad Edwards on behalf of E.W. as well, Judge. Thanks. Page

et al. 250 Australian Ave. South, Suite 1400 4 West Palm Beach, FL 33401 5 On behalf of the Defendant 6 ROBERT CRITTON, JR., ESQUIRE Burman, Critton, et al. 7 515 N. Flagler Drive, Ste. 400 West Palm Beach, FL 33401.4349 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 On

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video of Epstein being asked whether he had an “egg- shaped” penis became a youtube.com sensation. It first appeared on The Palm Beach Post Web site. Critton blamed attorney Spencer Kuvin for releas- ing it. Kuvin said it was “public record. The civil suits began mounting after Epstein agreed to plead gu