Epstein Secrets

ads). Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on March 19, 2010, the following exchange occurred: Mr. Kuvin: Okay. And what were the dates of the surveillance? Witness: [Referencing his Report] It appears she met with members of the B.S.F. unit, Burglary

st which delineates alleged victims. Once the NPA was made public, Judge Colbath, with the agreement of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private. As such, Request for Production Numbers 7, 9 and 10 seeks information that may violate others thi

conference. . . or when it becomes apparent that punitive damages can be awarded." Id. at *5. Since bifurcation is required in the instant matter, W.R. Grace & Company v. Waters, 638 So.2d 502 (Fla. 1994), it is reasonable and consistent with the applicable law, that any tax returns not be produced until such time

ads). Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on March 19, 2010, the following exchange occurred: Mr. Kuvin: Okay. And what were the dates of the surveillance? Witness: [Referencing his Report] It appears she met with members of the B.S.F. unit, Burglary

t of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private

l conference ... or when it becomes apparent that punitive damages can be awarded." Id. at *5. Since bifurcation is required in the instant matter, W.R. Grace & Company v. Waters, 638 So.2d 502 (Fla. 1994), it is reasonable and consistent with the applicable law, that any tax returns not be produced until such time

addressees on this 8th day of January, 2010: EFTA00599166 B.B. v. Epstein Case No. 2008CA037319XXXXMBAB Page 7 of 7 Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: 561 697 2383 Counsel for Plaintiff B.B. Jack Goldberger,

d Alternative Motion to Identify B.B. (the "Initial Motion"). In support, Epstein states as follows: 1. As stated in Epstein's Initial Motion, Mr. Kuvin continues to utilize this case and other related matters to "plug" himself and his firm and, in doing so, has brought direct attention to his clien

gages in conduct that is malicious, oppressive, or committed with such gross negligence amounting to wanton disregard for the rights of others. See W.R. Grace & Company v. Waters, 638 So. 2d 502 (Fla. 1994). 10. Before a Plaintiff may assert a claim for punitive damages, the trial court must determine that there