Epstein Secrets

a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this £ day of December, 2009: Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Fax: Counsel for Plaintiff'''. Jack Goldberger, Esq. ss, P.A. Fax: Co-counsel for Defendant Jeffrey Epstein EFTA00723231 v. Epstein Ca

's deposition was set for September 2, 2009, and Mr. Epstein was in attendance for said deposition. Directly after asking Mr. Epstein his name, Mr. Kuvin then asked Mr. Epstein, "[ijs it true, sir, that you have what's been described as an egg-shaped penis." Accordingly, Mr. Kuvin immediately set the

a discovery request is overly broad, burdensome or oppressive, by submitting evidence or offering evidence which reveals the nature of the burden." Coker v. Duke & Co., 1777 F.R.D. 682, 686 (M.D. Ala. 1998). Once the resisting party meets its burden, the burden shifts to the moving party to show the

Plaintiff conferred with counsel for the Defendants in a good faith effort to resolve the issues raised in this motion, but was unable to do so. s/ Spencer T. Kuvin Spencer T. Kuvin (Florida Bar Number 089737) Certificate of Services I hereby certify that on August 18, 2008, I electronically filed the foregoin

s motion, but was unable to do so. s/ Spencer T. Kuvin Spencer T. Kuvin (Florida Bar Number 089737) Ce

f South Alabama I American Tobacco Co., 168 F.3d 405, 411 (11th Cir. 1999) (citing Bums. Windsor Ins. Co., 31 F.3d 1092, 1095 (11th Cir. 1994), and Coker. Amoco Oil 3 EFTA00234426 Case 9:08-cv-80804-KAM Document 11 Entered on FLSD Docket 08)18:2008 Page 4 of 11 Co., 709 F.2d 1433 (11th Cir. 198

80, 08- 80381, 08-80993, 08-80994 Spencer Todd Kuvin, Esq. Theodore Jon Leopold, Esq. Leopold Kuvin,

an permeate everything: your sense of self, intimate relationships, sexuality, parenting, working, even your sanity.”)4 The U.S. Supreme Court in Coker v. Georgia, 433 U.S. 584, 597 (1977), discussed the grave nature of the crimes at issue in the cases against Defendant, stating: [Rape] is highly r

in, Michael) (Entered: 08/08/2008) 08/13/2008 9 r 274 KB Unopposed MOTION for Extension of Time to File CIVIL RICO CASE STATEMENT by Jane Doe. (Kuvin, Spencer) (Entered: 08/13/2008) 08/14/2008 I 0 ENDORSED ORDER granting 9 Motion for Extension of Time to File Civil Rico Case Statement. Signed b

on against any one of the resident defendants, the federal court must find that joinder was proper and remand the case to state court." Id. quoting Coker,. Amoco Oil Co., 709 F.2d 1433, 144041 (11th Cir.1983). The Florida Fifth District Court of Appeals set forth the elements of a civil conspiracy as