Epstein Secrets

te 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jagescabellsouth.net Counsel for Defendant Jeffrey Estein Farmer , Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 brad@cpathtoiusti

ely confidential or cloaked with a qualified immunity," and must, therefore, "balance the countervailing policies of liberal discovery set forth in the Federal Rules of Civil procedure against maintaining the confidentiality of such documents." Id. To achieve that balance, courts in the Second Circuit have developed a "m

d States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 E-mail: 5 EFTA00705606 Case 9:08-cv-80736-KA

initial disclosures required by the Federal Rules of Civil Procedure, including Rule 26(a)(1). Respondents object because the Court's finding that the Federal Rules of Civil Procedure "govern the general course of this proceeding," does not mean that all requirements governing 4 EFTA00705605 Case 9:08-cv-80736-KAM Do

ined the services of Thomas Marsigliano, a Private Investigator in New York, to make service on Epstein and one whom the law firm of Farmer, Jaffe, Weissing has been forced to pay $1,400.00, up to this point just to obtain service on Epstein. Declaration of Edwards - Exhibit 1 at 116-17. 3 EFTA00722413

al place of abode with Mark, a person of suitable age and discretion who resides there . . . ." 8. The foregoing service constituted proper service the Federal Rules of Civil Procedure. See Fed. R. Civ. P. 4(e)(2)(B). Under the Federal Rules of Civil Procedure, an answer to a properly served complaint must be filed withi

d States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: bra

rs. III. PETITIONERS HAVE NO RIGHT TO DISCOVERY UNDER THE FEDERAL RULES OF CIVIL PROCEDURE Petitioners argue they are entitled to discovery under the Federal Rules of Civil Procedure, but they point to no particular rule, or case, which provides that such a discovery rights exists. Instead, petitioners seize upon the g

WVVW.PATHTOJUSTICECOM Oro Tam Class Attie., Personal Injury Wrongful Death Commercial Liogation Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. January 29, 2015 Wilfredo A. Ferrer United States Attorney Southern District of Florida 99 N.E. 4th Street M

we are also writing to ask for your non-opposition to Jane Doe No. 3 and Jane Doe No. 4's motion to intervene in the case. As you know, Rule 24 of the Federal Rules of Civil Procedure allows intervention on two grounds: Mandatory intervention is allowed where a putative intervenor "claims an inter relating to the . . .

ffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. Farmer , Jaffe, Weissing, Edwards, Fistos Lehrman, PL Counsel for Plaintiff in Related Case No. 08- 23 EFTA00222464 Case 9:08-cv-80119-KAM Document 477 Entered on FLSD

ely confidential or cloaked with a qualified immunity," and must, therefore, "balance the countervailing policies of liberal discovery set forth in the Federal Rules of Civil procedure against maintaining the confidentiality of such documents." W. To achieve that balance, courts in the Second Circuit have developed a "mo

tion derived from documents or data over which a claim of privilege was asserted by or on behalf of Rothstein, Rosenfeldt, Adler PA; Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.; or Bradley J. Edwards? MR. LINK: I think -- which subpoena duces tecum are you looking at, Jack? Which case? MR

y questions about this subject during his deposition, as enumerated below. Relevant Legal Standards Under Federal Bankruptcy Rule 7030, Rule 30 of the Federal Rules of Civil Procedure applies in adversary bankruptcy proceedings of this type. Under Rule 30, a deponent can refuse to answer questions only to protect a priv

and 2 v. United States, Case No. 08-80736-CIV- United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe # 1 and Jane Doe #

itioners. PETITIONERS HAVE NO RIGHT TO DISCOVERY UNDER THE FEDERAL RULES OF CIVIL PROCEDURE Petitioners argue they arc entitled to discovery under the Federal Rules of Civil Procedure, but they point to no particular rule, or case, which provides that such a discovery rights exists. Instead, petitioners seize upon the g

d States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: bra

itioners. PETITIONERS HAVE NO RIGHT TO DISCOVERY UNDER THE FEDERAL RULES OF CIVIL PROCEDURE Petitioners argue they arc entitled to discovery under the Federal Rules of Civil Procedure, but they point to no particular rule, or case, which provides that such a discovery rights exists. Instead, petitioners seize upon the g