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s representing criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and t
RINE W. EZELL, ESQ. Podhurst Orseck Josefsberg 6 25 West Flagler Street Miami, FL 33130 7 For Jane Doe 101 305.358.2800 8 FOR THE DEFENDANT: ROBERT D. CRITTON, JR., ESQ. MICHAEL BURMAN, ESQ. 9 Burman Critton, etc. 515 North Flagler Street 10 West Palm Beach, FL 33401 11 JACK A. GOLDBERGER, ESQ. 12
n't been through all of them. But we do believe that there 6 has been a breach in the filing that Mr. Josefsberg referred 7 to, and contrary to Mr. Critton, we do understand that we have 8 an obligation to provide notice, and we are providing notice to 9 Mr. Epstein today. 10 The pleading that we fou
s representing criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and t
one) 5 KATHERINE W. EZELL, ESQ. Podhurst Orseck Josefsberg 6 25 West Flagler Street Miami, FL 33130 7 For Jane Doe 101 8 FOR THE DEFENDANT: ROBERT D. CRITTON, JR., ESQ. MICHAEL BURMAN, ESQ. 9 Burman Critton, etc. 515 North Flagler Street 10 West Palm Beach, FL 33401 11 JACK A. GOLDBERGER, ESQ. 12
n't been through all of them. But we do believe that there 6 has been a breach in the filing that Mr. Josefsberg referred 7 to, and contrary to Mr. Critton, we do understand that we have 8 an obligation to provide notice, and we are providing notice to 9 Mr. Epstein today. 10 The pleading that we fou
e attorneys representing criminals, the Office would promptly turn over all information in its possession that was helpful to these criminals under Brady' Maryland, 373 U.S. 83 (1963), and related decisions. Victims' counsel asked the Office to extend to the victims the same assistance that it would p
. .lawsuit[] 2 EFTA00177158 Case 9 08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 3 of 10 Letter from Bradley J. Edwards to Robert D. Critton, Jr., Case No. 9:08-CV-80893, Doc. #214 (attachment 2). On September 2, 2010, Epstein filed a motion for a protective order, seeking to bar disclo
s representing criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and t
of Epstein being asked whether he had an "egg- shaped" penis became a youttibe.com sensation. It first appeared on The Palm Beath 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
e attorneys representing criminals, the Office would promptly turn over all information in its possession that was helpful to these criminals under Brady v. Maryland, 373 U.S. 83 (1963), and related decisions. Victims' counsel asked the Office to extend to the victims the same assistance that it would
] . . .lawsuit[] EFTA00230174 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 3 of 10 Letter from Bradley J. Edwards to Robert D. Critton, Jr., Case No. 9:08-CV-80893, Doc. #214 (attachment 2). On September 2, 2010, Epstein filed a motion for a protective order, seeking to bar disclo
e attorneys representing criminals, the Office would promptly turn over all information in its possession that was helpful to these criminals under Brady. Maryland, 373 U.S. 83 (1963), and related decisions. Victims' counsel asked the Office to extend to the victims the same assistance that it would p
CV-MARRA 000928 EFTA00230752 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 3 of 10 Letter from Bradley J. Edwards to Robert D. Critton, Jr., Case No. 9:08-CV-80893, Doc. #214 (attachment 2). On September 2, 2010, Epstein filed a motion for a protective order, seeking to bar disclo
npersuaded by the letter and the presentation, but I agreed that I should carefully review transcripts of the recorded statements given to PBPD for Brady issues." Since witness credibility was clearly at the fore, I undertook efforts " The requested documents and items were never provided. 15 As the
ons 86 6/9/2009 Indictment package signed again for presentation on 6/16/2009 6/11/2009 Villafatia Katherine W. I lizell Email re letter from Critton Denying any fees and hearing on 6/12/09 6/12/2009 Goldberger \ illafafia Letter re violation of NPA 87 6/12/2009 Villafaila 1.efkowitz Lette
CLERK. 3/28/2023 2:27:00 PM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • J8RsEPSl I he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very I familiar with it. It is analogous. It is a situation where there was trem
a video of Epstein being asked whether he had an "egg-shaped" penis became a youtube.com sensation. It first appeared on The Palm Beach PostWeb site. Critton blamed attorney Spencer Kuvin for releasing it. Kuvin said it was .public record. The civil suits began mounting after Epstein agreed to plead guilty
Entities connected to both Brady and Robert D. Critton

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Alan Dershowitz
PERSONMichael J. Pike
PERSON
Paul Cassell
PERSON
Adam D. Horowitz
PERSONSouthern District
LOCATION
Kenneth Marra
PERSONRichard Horace Willits
PERSON
George W. Bush
PERSONRobert C. Josefsberg
PERSONMartin Weinberg
PERSONScott Rothstein
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONMaria Farmer
PERSONSpencer Kuvin
PERSON
Jeffrey Marc Herman
PERSON