Epstein Secrets

y Epstein and Co. (the "Defendants"), No. 113903/07 in New York Supreme Court, New York County, including, without limitation, Plaintiff's appeal of the Supreme Court's October 16, 2008 decision to dismiss the same, and all other proceedings relating thereto (the "Action"). (b) Within ten (10) business days after

are entering into this Agreement solely to avoid the inconvenience and unnecessary expenditure of time and resources associated with litigating the Action and any other matters among the Parties. All communications (whether oral, in writing or in electronic form), agreements, documents, or other mater

tein and Co. (the "Defendants"), No. 113903/07 in New York Supreme Court, New York County, including, without limitation, Plaintiff's appeal of the Supreme Court's October 16, 2008 decision to dismiss the same, and all other proceedings relating thereto (the "Action"). (b) Within ten (10) business days after t

are entering into this Agreement solely to avoid the inconvenience and unnecessary expenditure of time and resources associated with litigating the Action and any other matters among the Parties. All communications (whether oral, in writing or in electronic form), agreements, documents, or other mate

ictimize C.M.A . 9. Furthermore, C.M.A.'s treatment records from the Inc. and are protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee v. Redmond, 518 U.S. 1, 116 S.Ct. 1923 3 EFTA00201395 Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009

s disagreement between the parties is properly the subject of Defendant's Motion to Dismiss First Amended Complaint For Failure to State a Cause of Action, and Motion For More Definite Statement; Motion to Strike, and Supporting Memorandum of Law (D.E. 47) which is currently pending before this Court.

including objectors, i f any, has a right to appeal to, or seek reconsideration in, the California Court ofAppeal, the California Supreme Court, or the U.S. Supreme Court or; to the extent any appeals have been filed, they have been resolved or exhausted. The Superior Court of the State of California, County of Los A

il on Defendants' Counsel and Lead Class Counsel by February 16, 2012 and must and include the following information: (1) a heading referring to the Action; (2) your name, address, telephone number, email address, and the contact information for any attorney retained by you in connection with the object

recoveries against Epstein from various civil actions. Shortly before Epstein's complaint was filed, Edwards' partner, Rothstein, was disbarred by the Supreme Court of Florida, and charged by the United States Government with various federal crimes arising out of the scheme. Epstein eventually narrowed his claims

he facts to footnotes. In pertinent part, Epstein's affidavit alleged the following as probable cause for the filing of the complaint: I filed the Action against Rothstein and Edwards because, based on the facts described below and in the Summary Judgment Motion, I believed at the time of filing my o

R Document 181 Filed 06/22/23 Page 4 of 10 than $1.5 billion; and In re Halliburton Securities Litigation (13-317), in which BSF won two appeals to the U. S. Supreme Court before achieving a $100 million recovery. 13. Another notable case in which BSF was lead counsel is In re Auction House Antitrust Litigation (1:00

forth my background as a mediator to provide context for the comments that follow, and to demonstrate that my perspective on the settlement of this Action is rooted in significant experience in the resolution of complex litigation. As described below, this Action presented complicated legal, factual,

re, .'s treatment records from the Parent-Child Center, Inc. and Dr. Serge Thys are protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee'. Redmond, 518 U.S. 1, 116 S.Ct. 1923 3 EFTA00182846 Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009

s disagreement between the parties is properly the subject of Defendant's Motion to Dismiss First Amended Complaint For Failure to State a Cause of Action, and Motion For More Definite Statement; Motion to Strike, and Supporting Memorandum of Law (D.E. 47) which is currently pending before this Court.

te and unlikely"). In discussing Twombly, the Eleventh Circuit in Watts v. Fla. International Univ., 495 F.3d 1289, 1295 (111h Cir. 2007), noted - "The Supreme Court's most recent formulation of the pleading specificity standard is that 'stating such a claim requires a complaint with enough factual matter (taken a

s disagreement between the parties is properly the subject of Defendant's Motion to Dismiss First Amended Complaint For Failure to State a Cause of Action, and Motion For More Definite Statement; Motion to Strike, and Supporting Memorandum of Law (D.E. 47) which is currently pending before this Court.

tlement agreement constituted Page 10 an "implied waiver" of this privilege. Id at 622-26. The court began its analysis with a con- sideration of the Supreme Court's decision in Nobles, noting that that decision held that an attempt to make testimonial use of work product resulted in an implied waiver of the p

ose would be to sanction Rosenbaum for his alleged un- authorized disclosures of his clients' privi- leged information in his Request for Judi- cial Action and at the April 16 hearing, enjoin Rosenbaum from future similar con- duct, determine whether Rosenbaum vio- lated Florida Bar Rules of Professiona