Epstein Secrets

32034, 904.261.3693 doug. wyler@comcast .-net BY: DOUGLAS A. WYLER, ESQUIRE On behalf of the Defendant/Resp

hat they suffered psychological, ills after being paid to give him sexually-charged massages at his Palm Beach mansion when they were as young as 14. Hafele told Epstein's attorneys they c.ouldn't go on a fishing expedition. The medical records^ he said,, can't be sought until the women are asked whether

t they suffered psychological.ills after l?eing paid.to give him sexually-charged massages at his Palm Beach mahsionwheii they were as young as 14. Hafele t_old Epstein's attorneys they c.ouldn't go on a fish1ng expeditfon. The medical records, he said,. can!t be sought until the women are asked whethe

ken as true, would prompt a reasonably prudent person to fear that he could not get a fair and impartial trial from the judge.") (citing Hayslip v. Douglas, 400 So. 2d 553 (Fla. 4th DCA 1981)). EFTA00589660 "Where a motion for disqualification fulfills the procedural requirements of that rule, is su

's 14 deadlines. Id. at p. 144; lines 6-14. As Epstein asserts in his affidavit, he does not feel that he can receive a fair hearing before Judge Hafele, particularly in light of the Judge's repeated comments regarding his wealth, his choice of counsel, and his determination of his assertion of privi

Goldberger, Esq.,/Bruce E. Reinhart, Esq., MI Douglas M. McIntosh, Esq., McIntosh, Sawran, Peitz & Car

0 minutes Hearing on Defendant Epstein's Motion to Dismiss, for More Definite Statement, and to Strike Directed to Plaintiffs Complaint Dear Judge Hafele: Enclosed please find a copy of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, and to

r Associate 0.90 hrs 250.00 $225.00 McIntosh, Douglas M. Partner 0.30 hrs 300.00 $90.00 DISBURSEME

sentation in future depositions if needed 05/20/09 DMM Review and analysis of Order Dismissing (action) with Prejudice, signed 0.10 hrs by Judge Hafele, on May 13, 2009 05/20/09 CEB Analysis of executed Order Dismissing with Prejudice 0.20 hrs Total fees for this matter $315.00 DISBURSEMENTS

ck A. Goldberger, Esq.,/Bruce E. Reinhart, Esq. Douglas M. McIntosh, Esq., McIntosh, Sawran, Peitz & Car

0 minutes Hearing on Defendant Epstein's Motion to Dismiss, for More Definite Statement, and to Strike Directed to Plaintiffs Complaint Dear Judge Hafele: Enclosed please find a copy of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, and to

8, 1994. William H. Ogle, Ormond Beach, FL. W. Douglas Childs, Jacksonville, FL. Jonathan D. Kaney Jr.,

specific tangible need arises in a civil case the relief should be sought in that case.' In other words, the Civil cases which are in front of Judge Hafele is one forum that Judge Marra said go to it. Judge Marra did not say that this Court does not have Jurisdiction to unseal its own sealed records or