Epstein Secrets

es nos. 1-11; and (iv) such other and further relief as this Court deems just and proper. Dated: March 18, 2010 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattor

earns & Co., Inc. v. Wyler, 182 F.Supp. 2d 679, 683 (N.D.Ill. 2002). Specifically, production of the documents at issue in Hubbell, concerning the Whitewater investigation, was itself an admission that the defendant had failed to comply with a plea agreement. Id.; Hubbell, 530 U.S. at 36-44. Here, unlik

Epstein be ordered to answer interrogatories and produce responsive documents. Dated: April 20, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MER

the respondent was in compliance with a plea agreement-resulting from the first investigation-requiring him to produce information relating to the Whitewater investigation. If the respondent had produced such information in response to the subpoena, it would have constituted testimony that he had Whitew

ordered to answer interrogatories and produce responsive documents. Dated: April 20, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. At

the respondent was in compliance with a plea agreement-resulting from the first investigation-requiring him to produce information relating to the Whitewater investigation. If the respondent had produced such information in response to the subpoena, it would have constituted testimony that he had Whitewa