DOJ-OGR-00000556.jpg

Case 1:19-cr-00490-RMB Document36_ Filed 07/24/19 Page 46 of 74 46 1 Attorney's Office. So Lanna Belohlavek who was the head of the 2 sex offender unit of Mr. Kirshner's state attorney's office. 5 Mr. Goldberger -- again, this is hearsay, and 4 Mr. Goldberger can attest to it, if it's necessary -- was never 5 asked about this alleged incident. 6 The investigators, certainly not authorized by 7 Mr. Epstein, to go and drive people off the road. There is 8 simply no proof that he authorized it or until discovery knew 9 it. There was no charge against an investigator which 10 contend there would be, given the intensity of this 11 investigation in Florida. 12 can't explain what the facts are. I see the report. 13 see the claim. But if the state attorney believed that a L representative of Mr. Epstein drove a parent off the road, I 15 don't think that would be missing in the negotiations between 16 his new counsel. 17 Then Mr. Goldberger was joined by Roy Black, a Miami 18 attorney who know well. Mr. Black has never been asked about 19 it or told about it and does not know the investigator. 20 Mr. Goldberger doesn't know the investigator. I have no other 21 explanation, other than it doesn't rise to clear and convincing 22 evidence. 23 In terms of the wires that the government think 24 that the government's language on page 11 of their submission, 25 your Honor, is most telling in terms of whether these wires SOUTHERN DISTR CT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000556