Epstein Secrets

in an article published over four years ago. The Court should disregard Mr. Cassell's affidavit in determining the Injunction Motion. See~ U.S. v. Baker, 432 F.3d 1189, 1211-12 (11th Cir. 2005) (holding that newspapers articles were inadmissible double hearsay when offered to prove the truth of their

FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 [email protected] kezell@p

ane Doe #6's mother told police that she tried to help Jane Doe #6 by placing her in Growing Together Treatment Program on 3/10/06 and by having her Baker Acted on 4/7/06. See Exhibit "L" Then, on 12/22/06, Jane Doe #6 and her then boyfriend, James Sullivan, got into an argument and he went out into t

FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 [email protected] kezell@p

h her father since the age 13 and also did Xanax Ex. "F" at 'l['l[l9 7 27. Plaintiff was placed in Growing Together Treatment Center on 3/10/06 and Baker Acted her on 4/7 /06. Id. Plaintiff has also been in several physical altercations with family and friends. Ex. "F" at 20-22. In particular, back

FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 18 Case 9:08-cv-80119-KAM Document 247 Entered

l not put him in a better position than he would be in had the wrong not been done or the contract not been broken. See also recent case of U.S. v. Baker, 2009 WL 4572, at *8, (E.D. Tx. Dec. 7, 2009), wherein the Court was inclined to agree with the defendant's interpretation of §2255(a) of allowing

l counsel of record identified on the following Service List in the manner specified by CM/ECF on this day of , 2010. Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldbe

l not put him in a better position than he would be in had the wrong not been done or the contract not been broken. See also recent case of U.S. v. Baker, 2009 WL 4572, at *8, (E.D. Tx. Dec. 7, 2009), wherein the Court was inclined to agree with the defendant's interpretation of §2255(a) of allowing

l counsel of record identified on the following Service List in the manner specified by CM/ECF on this day of , 2010. Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 [email protected] kezell@p

an article published over four years ago. The Court should disregard Mr. Cassell's affidavit in determining the Injunction Motion. ate ?di U.S. v. Baker, 432 F.3d 1189, 1211-12 (11th Cir. 2005) (holding that newspapers articles were inadmissible double hearsay when offered to prove the truth of their

r Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. Bruce Reinhart, Esq. Counsel for Plaintiffs in Related Cases EFTA00221951 Case 9:08-cv-80119-KAM Document 198 Ent

NPA? 6. Whether damages are to be awarded based on injury to a plaintiff or based on the number of separately proven claims, see United States'. Baker, 2009 WL 4572785 (E.D.Tex., 2009) where the Court rejected the contention that damages were to be allocated per violation? We are not asking the go

of right by a jury. Date: C44.ArtatA4-1.2)-3 , 2010. Respectfully Submitted, By: iRreat fia—Plef'-b W4P/ Robert C. Jose erg Bar No. 040856 Katherine W. Ezell Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler St., Suite 800 Miami, Florida 33130 Telephone: (305) 358-2800 Fax: (305) 358-2382 rjosefs

ill not put him in a better position than he would be in had the wrong not been done or the contract not been broken. See also recent case of U.S. Baker. 2009 WL 4572, at *8, (E.D. Tx. Dec. 7, 2009), wherein the Court was inclined to agree with the defendant's interpretation of §2255(a) of allowing

triable as of right by a jury. Date: 4artitA4-1-i-3 , 2010. Respectfully Submitted, By: ke-PO4 fe-Peet-vbv Robert (.Jose erg Bar No. 040856 Katherine W. Ezell Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler St., Suite 800 Miami, Florida 33130 Telephone: (305) 358-2800 Fax: (305) 358-2382 sefsber

ill not put him in a better position than he would be in had the wrong not been done or the contract not been broken. Sec also recent case of U.S. Baker, 2009 WL 4572, at *8, (F.D. Tx. Dec. 7, 2009), wherein the Court was inclined to agree with the defendant's interpretation of §2255(a) of allowing

ll issues triable as of right by a jury. Date: ‘44..Art.AA-r-12)-3 , 2010. Respectfully Submitted, By: R-W- C. e-pecli lay Robert r Jose e g Katherine W. Ezell Attorneys or Plaintiff Podhurst Orseck, P.A. 17 25 West Hagler Street, Suite 800„ Miami, FL 33130, Miami 31:6393.2800 Fax 305.358.2382 • Fort Lau