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epstein court records
← Back to MJ v. Epstein, No. 9;10-cv-81111 (S.D. Fla. 2010)
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UNITED DISTRICT COURT SOUTHE-3.4RN DISTRICT OF FLORIDA JANE NO CASE NO 80119-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE NO CASE NO 80232-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE NO CASE NO 80380-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO JANE NO CASE NO 80381-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE NO CASE NO 80994-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE NO CASE NO 80993-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO CASE NO 80811-MARRA/JOHNSON C.M.A Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE CAS-3.5E NO 93-CIV-MARRA/JOHNSON Plaintiff Vs JEFFREY EPST-4.5EIN et al Defendant DOE CASE NO 80469-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-4.5EIN et al Defendants-5.6.-2.8 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO JANE DOE NO CASE NO 80591-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE DOE NO CASE NO 80656-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 PLAINTIFF JANE MOTION TO CO MPEL ANSWERS TO PLAINTFF?S FIRST REQUE-3.6S1.4T FOR PRODUCTION Plaintiff Jane Doe hereby this Court for an order compelling-4.1 def-7.4endant Jeffrey Epstein to answer her first request fo production or in the alternative to prove that his invocation of his Fifth Amendment privilege proper Jane Doe also requests production of a privilege log 2119Jane Doe has propounded reques-5.1ts for production including-4.5 such straightforward requests as requests for production of Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO 2720Request No Copies of all telephone records 2630Request No Photos of the inside of your home loca-4.5ted at El Brillo Palm Beac-5.6h Florida that depict the room where ma ssages took place including massage table 2720Request No Correspondenc-5.8e between Epstein and federal prosecutors 2720Request No Personal tax returns 2720Request No Photocopies of Epstein?s passport Request No A statement of net worth and 2720Request No Medical records response to each and every one of these requests Epstein has given the following response with only mino variations here and there Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution Court should order Epstein to provi de all of the requested information or in the alternative prove that hi Fifth Amendment invocations ar valid It is for the court not the claimant to determine whether the hazard of incriminatio is justifie-4.1d United-4.7 States Argom8.5a1.7niz F.2d 11th Cir A court must make a particulariz-5.3ed inquiry-5.3 deciding,-7.5 in c-5.3onnect ion with each s-4.9p-3.7ecific area that the Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO questioning party wishes to explore whet her or not the priv ilege is well-founded Id Typically t-8h.4is done in an proceeding wherein he person asserting the privilege given the opportunity to substantiate claims of the privilege and the district court is able to consider the ques tions asked and the doc-5.3uments requested by the summons Id 2570Here Epstein has made boilerplate invo cation of the Fifth Amendment to each and ev-5.2ery request propounded by Jane Doe including-3.8 for example the request correspondence with federal pros-5.3ecutors and for pr oduction of federal tax returns This obvious-5.5ly is not a request with Fifth Amendment implications as the information already been fully dis-5.1c-.1losed to the Government all thes-5.3e reasons the Court should c-5.3o.9mpel Epstein-4.2 to answer the requests provide a particulariz-5.3ed justification for hi Fifth Amendment inv-5.3o.9cation wit-7.5h regard each request Epstein?s and paste response to th request for production also blat-8antly disregards the requirements for invoking privile ge under the Court?s local rules Local rule very specifically requir-7.2e1s the prep aration of a privilege lo with respect to all documents and oral communications among ot her things that are withheld on the basis of pr-7.3ivilege Epstein failed to pr epare a log making it im-7.5possible Jane Doe to effectively chall enge his generic assertions Indeed with respect to a few requests Epstein has stated Further the request may include information subject to work product or an attorney-client privilege Of course the whole purpose of forcing a defendant prepare a priv ilege log is to force the def endant to decide whether or not Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO information is privileged An assertion that something may be privileged is obvious-5.2ly-5.2 woefully deficient The Local Rules do not pe rmit this tactic and Ep stein should be at a minimum promptly required to produce a privilege log all thes-5.4e reasons the Court should co m-7.5pel Epste-4.4i1.7n to provide a privilege log and to ans-5w2.2er the interrogatories or provide a particularized justif ication his Fifth Amendment invocation with regard to each request It should be noted that with minor except ions the only grounds on which can refuse to answer the request for produc tion is proof of a valid Amendment privilege This the only objection Epstein has asserted with minor exceptions As a result any other objections to production are deemed waiv-5ed Local Rule-9.8 a Any ground for an objection not stated in an objection within the time provided by the Federal Rules of Civil Proc-5.7edur or any extens-5.2ions thereof shall be SPE-3.8CIFIC FOR PRODUCTION For the convenience of the court and in complianc-5.3e with Local Rule party filing-4.2 motion to compel sh-4.2all list spe-4.2c ific reque-4.2sts in succ-5.4ession Jane requests for production and Epstein?s object-7.5i1.9ons are as follows Request No Copies of all telephone in your or your attorney?s possession from through that in any way relate to you inc luding all phone lines owned by you or that were used to contact girl for the purposes of scheduling massages you Defendant-7.7 is asserting his U.S cons titutional priv-5ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution Request No All massage appointm-7.5ent boo ks diaries computer calendars scheduling entities scheduling books-5.1 or any other writing correspondence contains the names of any of the girls that were called contacted scheduled or otherwise went to your home loca ted at El Brillo Way Pa lm Beach Florida for the purpose of giving you a massage Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution Request No Any and all doc-5.2umentation in your possession that contains-5.1 Plaintiff?s-5.1 name or that refers Plaintiff directly or indirectly includes e-mails letters5.7 message pads diaries appointment books computer print outs Defendant-7.7 is asserting his U.S cons titutional priv-5ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.4erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution Request No Any and all photos videos dow nloade-3.9d digital prints or any other visual depiction of Plaintiff or of any other know or suspected minor females introduced to you directly or indirectly by Plaintiff Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional righ-3.9ts under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution Request No Photos of the inside or your home located at El Brillo Way Palm Beach Florida that depict the room where massages too plac-5.7e massage table Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution Request No Any and all doc-5.1umentation of cancelled checks or evidence of payment to Plaintiff of any kind and for any reason whatsoever Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be unr easonable and would therefore violate the Constitution Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO Request No All discovery information obtai ned by you or your attorneys as a result-7.8 of the exc-5.2hange of discovery in the Stat-7.6e criminal case aga-3.8inst you or the Federal investigation against you Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution In addition to and without waiving his cons-5.3titutional privileges the information sought is pr-7ivileged and confidential and inadmiss-5.2i2ble to the terms of the def erred prosecution agreement Federal Rule of Ev-5.6idence and and Fla Stat Further the request may including information subjec to work product or an attorney client privilege Request No All financial documents evidenci ng ass-5.2e1t transfers from to present-7.4 for you personally or any company or corporation owned by you Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.4erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution Ja5.4ne d5.4oes not to mate5.4rial6.7s forb5.4idden5.4 inferen5.4c-2.9e 6of guilt the fact that information wa5.3s p5.3r-2.3ovided to la5.4w enforcem6.8e5.4nt officials as part of plea discu5.9ssi7.2on5.9s but for other m6.9a-.5terial6.8s are al6.8so quite likely to to the disco4.9v2.6ery of other 6admissibl6.2e4.9 eviden5.5ce as 6they relate to the same su5.5bject matter 6as this la5.3wsui6.6t To the extent that Epstein relie5.2s on the non5.1-prosecutio5.1n-.9 agre5.1e-.9ment nothi6.4ng in that agreement b5a-.9rs disco4.8v-3.5ery of i6.2n-1.1formatio4.8n re4.9levant to this laws-4.7uit Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO Request No Any documents or other evidentiary materials provided to local state or federal law enforcement investigators or local st ate or federal prosecutors investigating your sexual activities with minors Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution In addition to and without waiving his cons-5.3titutional privileges the information sought is pr-7ivileged and confidential and inadmiss-5.3i1.9ble pursuant to the terms of the deferred prosecution agr-7.2eement Fed Rule of Evidenc-5.2e1 and Fla Stat Further the request may include in for-6.8m-1.8ation subject to work product or an attorney-client privilege Request No All correspondence betw een and your atto rneys and state or federal law enforcement or pr osecutors includes but not limited to letters to and from the States Attorney?s offi ce or any agents thereof Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution In addition to and without waiving his cons-5.3titutional privileges the information sought is pr-7ivileged and confidential and inadmiss-5.3i1.9ble pursuant to the terms of the deferred prosecution agr-7.2eement Ja5.4ne d5.4oes not to mate5.4rial6.7s forb5.4idden5.4 inferen5.4c-2.9e 6of guilt the fact of plea 6discu5.4ssi6.7on5.4s but for other 6material6.7s also li6.7kely to lead to discovery8.8 othe5.1r a5.1d-.9missible5.1 evide5.1n-.9ce the5.1 extent that 6Epstein5.5 th5.5e agre5.1e-.9me5.1nt nothing in that agre5.1e-.9me5.1nt bars of information relevant to this-3.9 lawsuit Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO Fed Rule of Evidenc-5.2e1 and Fla Stat Further the request may include in for-6.8m-1.8ation subject to work product or an attorney-client privilege Request No Any and all doc-5.3uments re fl7.4ecting your current net worth Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution Request No Personal tax returns fo all years from through the present Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be unr easonable and would therefore violate the Constitution overly broad Request No A photocopy of your pa ssport including any supplemental pages-5.5 reflecting to locations outside th United States bet ween and including any documents or records regar ding plane tick-5.3ets hotel receipts or transportati7.4on arrangements Ja5.4ne d5.4oes not to mate5.4rial6.7s forb5.4idden5.4 inferen5.4c-2.9e 6of guilt the fact of corre5.5s-2.8po5.5nde5.5nce in with plea di scussio5n-1s b5u-1t rather fo5r other These5 material6.6s are also likely to lead to the discovery of ot h6e0r admi7.3ssi7.3ble6 evidence To the extent that Epstein5.1 relie5.3s on th5.3e 6non-prosecution ag5.3ree5.3m en5.3t nothing in t8.4hat agreem6.7e5.3n-.7t bars di6.3sco5v-3.3ery 6of inform6.8ation rel6.7e-.6vant to this-4.3 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be unr easonable and would therefore violate the Constitution In addition to and without waiv-5.2ing his c-5.2o.9nstitutional protections and privileges the sc-5.5ope of information is overbroad that seeks information that is neither ant nor reasonably calculated to le-3.8ad to the discovery of admissible ev-5.8idenc co-4.3mpilin-4.4g such information over a six year period would be unduly burdensom-7.8e and time consuming Request No A statem ent of your net wort-7.2h incl uding a detailed financ-5i2.2al statement depicting all current assets and liabilities Defendant-7.5 is asserting his U.S constituti onal priv-5.3ileges I intend to respond to relevant questions regarding this-5.6 lawsuit however my attorneys have counseled that at the present time I cannot select authenticate and produce documents relevant to this lawsuit-7.2 and I accept this advice or risk my Sixt Amendment right to effective representation Acco rdingly I my federal constitutional rights under the Fifth Sixt-7.5h and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse infe rence under these circumstances would unconstitutionally bur-7.5den my exercis-5.5e.7 of my constitutional rights would be unreasonable and would therefore violate the Constitution Request No All financ-5.3ial statements or affidavits produced by you for any reason to any person company entity or corporation since Defendant-7.7 is asserting his U.S cons titutional priv-4.9ileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United Ja5.3ne b5.3e5.3lieves th5.3at Ep5.3stein 6used 6oversea5.3s-3 travel as 6a obtainin6.3g.3 6girl7.6s 6sexual purp5.7o-.3ses for avoiding 6crimi7nal p5.7r-1.9osecutio5.7n for su5.7ch a5c-3.3tivities Also providi6.3n5g a co5py of a passpo5r-2.6t is hardly given the fa5.1ct that Ep5.1stei6.4n is li6.5kely th5.1e of 6a 6travel ag5.2ent or 6anoth5.3e-.7r i6.6n-.7terme5.3d-.7iary it 6not difficult fo5.3r hi to 6eviden5.2ce 6of travels intermediaries-4.6 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO States Constitution Drawing an adv-5.3erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution overly broad Request No All medical rec-5.3o.9rds of De fendant from Stephan Alexander Defendant-7.7 is asserting his U.S cons titutional priv-5ileges I intend to respond to all relevant questions egarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relev ant to this lawsuit I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.4erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution CONCLUS-2.7ION all thes-4.9e reasons the Court s-4.9hould com-6.8pel Epstein to answer the request for production,-7.4 or provide a particularized justif ication for his Fifth Amendment invocation with regard to each request Eps-5t-2.2ein should also be re-3.8quired to provide a privilege log Counsel for Jane Doe have rred with opposing c-5.2o.9unsel on he iss-5.5ues r-7.5a.7ised this motion and no resolution was possible DATED July 2720Respectfully Submitted Bradley Edwards Bradley Edwards ROTHST-5.3EIN ROSENFELDT Las Olas City Centre East Las Olas Blvd Suite Fort Lauderdale Florida Telephone Facsimile Florida No E-mail bedwards rra-law.com Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO and Salt 2720Lake 2720City Telephone:-7.7 Facsimile:-7.7 cassellp law.utah.edu CERTIFICATE OF SERVICE HEREBY CERTIFY that on I electr-6.6onically filed the foregoing document with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all part ies on the attached Service List in the manner specified either via transmission of Notices of El ectronic Filing generated by CM/ECF or in some ot-7her authorized manner for those parties who are not authorized receive electronically filed Notices of Electronic Filing Bradley Edwards Bradley Edwards Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CASE NO SERVICE LIST Jane Doe Jeffrey10.8 Epstein United States District Court Southern District of Florida Jack Alan Goldberger-7.5 Esq Jgoldberger agwpa.c-5.1o1.1m Robert Critton Esq rcritton bclcla-4.3w.com Isidro Manual Garcia isidrogarcia bells-5.2outh.net Jack Patrick Hill iph searc-5.7y-.7law.com Katherine Warthen Ezell KEzell podhurst.com Michael James Pike MPike bclclaw.com Paul Cassell cassellp Richard Ho-4.5race Willits-5.7 lawyerswillits aol.com Robert Josefsberg rjosefsberg podhurst.com Adam Horowitz ahorowitz-5.6 5sexabus-5.6eattorney.com Stuart Mermelstein-4.1 ssm sexabuseattorney.com William Berger wberger rra-law.com Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of
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