Epstein Secrets

I'm assuming Counsel is not 22 asking you to divulge attorney/client 23 MR. TEIN: Of course not. 24 BY MR. TEIN: 25 Q. a are you aware that Jeffrey Herman, Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 3801316 EFTA00234261 Case 9:08-cv-8080

it is clear that the plaintiff seeks damages in connection with her own illegal conduct; this is enough to support a finding of fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 n.3 (11th Cir. 2007) (acknowledging that "under some circumstances, application of an affirmative defense can support a f

I'm assuming Counsel is not 22 asking you to divulge attorney/client 23 MR. TEIN: Of course not. 24 BY MR. TEIN: 25 Q. a are you aware that Jeffrey Herman, Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Sulte 500 - West Palm Beach, FL 33401 MI of 311 EFTA00180444 Case 9:08-cv-80

it is clear that the plaintiff seeks damages in connection with her own illegal conduct; this is enough to support a finding of fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 n.3 (11th Cir. 2007) (acknowledging that "under some circumstances, application of an affirmative defense can support a f

ney/client privilege. 21 22 asking you to divulge attorney/client -- 23 MR. TEIN: Of course not. 24 BY MR. TEIN: 25 Q. a are you aware that Jeffrey Herman, Any conversations that you and I have had MR. LEOPOLD: I'm assuming Counsel is not Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm

it is clear that the plaintiff seeks damages in connection with her own illegal conduct; this is enough to support a finding of fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 n.3 (11th Cir. 2007) (acknowledging that "under some circumstances, application of an affirmative defense can support a f

m assuming Counsel is not 22 asking you to divulge attorney/client -- 23 MR. TEIN: Of course not. 24 BY MR. TEIN: 25 Q. a are you aware that Jeffrey Herman, Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 31 d711 EFTA00232170 Case 9:08-cv-80804-KAKI ent 1 Entered on

it is clear that the plaintiff seeks damages in connection with her own illegal conduct, this is enough to support a finding of fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 n.3 ( I I th Cir. 2007) (acknowledging that "under some circumstances, application of an affirmative defense can support