Epstein Secrets

Infliction of Emotional Distress," such claims are subject to the constitutional limitations and guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Liqoet Group, In

City National Bank Building 25 W Flagler Street Suite 800 Miami FL 33130-1780 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED represented by Robert Deweese Critton , Jr. Burman Critton Luttier & Coleman https://ecf.flsd.useourts.gov/egi-bin/DIctRpt.p17825839498761356-L_801_0-1 6/10/2009 EFTA00175220 CM/ECF

/04/2009) 05/11/2009 5 r RESPONSE/REPLY to 4 Sealed Document, 3 Sealed Document Opposition to Motion to Proceed Anonymously by Jeffrey Epstein. (Critton, Robert) (Entered: 05/11/2009) 05/11/2009 6 r NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf of Jeffrey Epstein (Critton

know is, was there 14 ever a tine that Mr. Rothstein offered 5200 million dollars to settle the three cases being prosecuted by the law firm you gore a shareholder in? I/ A Not to my knowledge. IS Q Did Hr. Epstein, during the tine you were a 1/ shareholder at the Rothstein firm, ever offer

as representing Mr. Epstein while you were involved? 21 A well, lack Goldberger and the Luttier firm, I 22 believe. 33 0 Bob Critton. 24 A Critton. 23 0 Dld you know Bob Critton? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798358 89 91 A Causally. 2 0 What was Kr. Crltton'

2:17 56:10 98:25 110:21 111:19 criminals 112:1 criticism 45:20 161:10 Critton 88:23,24,25 89:14,17 114:4 116:18 118:24,25 119:1,1,19 134:19 Critton's 89:2,6 116:3 crook 147:21 cross-examination 3:6 54:23 55:7 cruise 21:8,10 current 3:18 currently 12:22 custody 12:13 cut 11:23 D D 2:2 3

she said. 'We'd do family things, like watch Sex And The City and eat popcorn. 'A lot of it was very glamorous. I met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. He introduced me as his "travelling masseuse.' Some people mistook me for his daughter. 'When we were in New Yor

lamorous. I met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. He introduced

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

ideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Willi

Epstein Respectfully sub By:---;--.,,--.,...--- ROBERT D CRITTON, JR., ESQ. Florida Bar o. 224162 rcrit@bclclaw.

first offender . . . [because] repeated misconduct is more reprehensible than an individual instance of malfeasance." BMW of North America, Inc. v. Gore, 517 U.S. 559, 577 (1996) (supporting citations omitted). In addition, juries can consider other similar acts evidence as part of the deterrence ca

ffort to resolve the issues set forth herein. Plaintiff's position is that the parties have already complied with the mediation requirements. By: s/Robert D. Critton, Jr. Robert D. Critton, Jr. Michael J. Pike Attorneys for Defendant Epstein EFTA00725996 Case 9:08-cv-80893-KAM Document 168 Entered on FLSD D

Infliction of Emotional Distress,° such claims are subject to the constitutional limitations and guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Ligget Group, In

. Accordingly, Plaintiff's cause of action thereunder is barred. WHEREFORE Defendant requests that this Court deny the relief sought by Plaintiff. Robert D. Critton, Jr. Attorney for Defendant Epstein EFTA00221254 Case 9:08-cv-80232-KAM Document 115-2 Entered on FLSD Docket 06/09/2009 Page 10 of 10 Jane D

Infliction of Emotional Distress," such claims are subject to the constitutional limitations and guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996)• Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Ligget Group, In

. Accordingly, Plaintiff's cause of action thereunder is barred. WHEREFORE Defendant requests that this Court deny the relief sought by Plaintiff. Robert D. Critton, Jr. Attomey for Defendant Epstein EFTA00221886 Case 9:08-cv-80119-KAM Document 148-2 Entered on FLSD Docket 06/09/2009 Page 10 of 10 Jane Do

ce of malfeasance." BMW of North America, Inc. I. Gore, 517 U.S. 559, 577 (1996) (supporting citations

ICE LIST Jane Doe I. Jeffrey Epstein United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. Jooldberaeraaawpa.com Robert D. Critton, Esq. [email protected] Isidro Manual Garcia [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected]

Infliction of Emotional Distress," such claims are subject to the constitutional limitations and guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996)• Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007)• State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Ligget Group, In

119-MARRA/JOHNSON SERVICE LIST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. Robert D. Critton, Esq. Isidro Manual Garcia Innle ' Katherine Warthen ell Michael James Pike Paul G Cassell Richard Horace Willits Robert C. Josefsberg Adam