Epstein Secrets

DATE &TIME Jane Doe #4 September 16, 2009 c/o Mermelstein & Horowitz PA at 1:00 PM 18205 Biscayne Bouleva

aintiffs generally rely on treatise material from Wright & Miller, 8 Federal Practice & Procedure Civ.2d, §2041, a

Response to Motion, to Compel Answers to Interrogatories and Production of Documents by Jane Doe No. 4. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/03/2009) 04/06/2009 71 Defendant's MOTION for Extension of Time to File Response as to 21 MOTION for Protective Order Agains

Entered. FLSD Docket 10/ ?008 Page 4 of 10 Case No. CV-80380-Marra-Johnson Page No. 4 Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller) ("[T]he pleading must contain something more ... than ... a statement of facts that merely creates a suspicion [of] a legally cognizable right of

Response to Motion, to Compel Answers to Interrogatories and Production of Documents by Jane Doe No. 3. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/03/2009) 04/06/2009 61 Defendant's MOTION for Extension of Time to File Response as to $1 MOTION for Protective Order Agains

ht to relief above the speculative level, see 5 C. Wright & A. Miller, Federal Practice and Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller) C[T]he pleading must contain something more ... than ... a statement of facts that merely creates a suspicion [of] a legally cognizable right of a

telephone or view a videofeed of the deposition, but will not be seen by our client. Regards, Adam D. Horowitz, Esq. WvAv.sexabuseattorney. C0111 Mermelstein a Horowitz, P.A. 18206 Biscayne Boulevard Suite 2218 Miami, FL 33160 Tel: Fax: From: Michael J. Rice [mato: Sent: Tuesday, September 15, 2009

to prevent the Defendant from being present in the room where the Plaintiffs are being deposed, Plaintiffs generally rely on treatise material from Wright & Miller, 8 Federal Practice & Procedure Civ.2d, §2041, and cases cited therein. The case of Oaella v. Onassis 487 F.2d 986, at 997 (2d Cr. 1973), cited by

to 62 Response to Motion, to Compel Answers to Interrogatories and Production of Documents by Jane Doe. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/03/2009) 04/06/2009 71 Defendant's MOTION for Extension of Time to File Response as to 66 MOTION for Protective Order and t

terer, ...i FLSD Docket 10i„,2008 Page 4 of 10 Case No. CV-80119-Marra-Johnson Page No. 4 Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller) ("[T]he pleading must contain something more ... than ... a statement of facts that merely creates a suspicion [of] a legally cognizable right of