Epstein Secrets

e, Overrule Objections, and for an Award of Reasonable Expenses be denied in their entirety. Dated: May 6, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattor

ot only the admissibility of evidence at trial, but must also “inform the discovery process.” Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996). The 3 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 3 of 10 Committee Notes state, in relevant part, a

Interrogatories and for an Award of Reasonable Expenses be denied in their entirety. Dated: May 6, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERME

ot only the admissibility of evidence at trial, but must also “inform the discovery process.” Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996). The Committee Notes state, in relevant part, as follows: Courts should presumptively issue protective orders barring discovery unless the

9, 2009. Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245)

a v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996) (granting protective order pursuant to Rul