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

e theory of the requestor's case, or to some significant aspect of the case); Ashemimry v. Ba Nafa, 847 So.2d 603 (Fla. 5th DCA 2003). In addition, Florida Rule of Civil Procedure 1.280(b)(3), does allow discovery of fact work product where the requesting party can show need and the inability to obtain the substantia

REBY CERTIFY that a true copy of the foregoing instrument has been furnished by facsimile and United States mail to Theodor J. Leopold, Esquire and Spencer T. Kuvin, Esquire, Leopold-Kuvin, P.A., 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, Florida 33410; Jack Alan Goldberger, Esquire, Atterbury Goldberg

il to Theodor J. Leopold, Esquire and Spencer T. Kuvin, Esquire, Leopold-Kuvin, P.A., 2925 PGA Boulevard

tment Record Custodian (collectively 'Town of Palm Beach Police Officers"), hereby move to quash the subpoena or for a protective order pursuant to Florida Rule of Civil Procedure 1.280(c) directing that discovery sought by the civil subpoenas for deposition issued by Plaintiff, B.B , and the cross-notices with subp

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

AMAGES Plaintiff, B.B., by and through undersigned counsel, and files this Motion for Leave to Amend Complaint to Seek Punitive Damages pursuant to Florida Rule of Civil Procedure 1.190(f) and F.S. § 768.72 and as grounds therefore, states as follows: R.I.C.O. 1. This is an action currently includes a cause of act

rdale, FL 33394, JACK A. GOLDBERGER, ESQ., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, SPENCER T. KUVIN, ESQ., Leopold-Kuvin, P.A., 2925 PGA Blvd., Suite 200, Palm Beach Gardens, FL 33410, and DEANNA K. SHULLMAN, 09/1212019 3 Pa n CONFIDENTIAL Agen

e, Suite 400, West Palm Beach, FL 33401. LEOPOLD—KUVIN, PA 2925 PGA Boulevard Suite 200 Palm B Garde

EPSTEIN, JEFFREY F, Defendant MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, B.B. and requests this Court, pursuant to Florida Rule of Civil Procedure 1.230, for leave to intervene as a party in Mr. Epstein's criminal matter for the following reasons: I. Applicant's intervention is in

e, Suite 400, West Palm Beach, FL 33401. LE0P0LD-KUVIN, P.A. 2925 PGA Boulevard Suite 200 Palm Be Ga

rdale, FL 33394, JACK A. GOLDBERGER, ESQ., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, SPENCER T. KUVIN, ESQ., Leopold-Kuvin, P.A., 2925 PGA Blvd., Suite 200, Palm Beach Gardens, FL 33410, and DEANNA K. SHULLMAN, EFTA00180822 400 North Ashley Drive,

TEIN, JEFFREY E, Defendant. 1VIOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, B.B. and requests this Court, pursuant to Florida Rule of Civil Procedure 1.230, for leave to intervene as a party in Mr. Epstein's criminal matter for the following reasons: 1. Applicant's intervention is in

rdale, FL 33394, JACK A. GOLDBERGER, ESQ., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, SPENCER T. KUVIN, ESQ., Leopold-Kuvin, P.A., 2925 PGA Blvd., Suite 200, Palm Beach Gardens, FL 33410, and DEANNA K. SHULLMAN, 3 EFTA00231322 400 North Drive, Su

Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of M., Mr. Kuvin, Esq. was present on behalf of M., Assistant State Attorney Barbara Burns was present-on behalf-of-the State of Florida; -No appearance was filed o

EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, M. and requests this Court, pursuant to Florida Rule of Civil Procedure 1.230, for leave to intervene as a party in Mr. Epstein's criminal matter for the following reasons: 1. Applicant's intervention is in

dale, FL 33394, JACK A. GOLDBERGER, ESQ., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, SPENCER T. KUVIN, ESQ., Leopold-Kuvin, P.A., 2925 PGA Blvd., Suite 200, Palm Beach Gardens, FL 33410, and DEANNA K. SHIJLLMAN, 3 EFTA00232442 400 North Drive, S

Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of M., Mr. Kuvin, Esq. was present on behalf of Assistant State-Attorney Barbara Burns-was present on behalf-of-the State-of Florida. No appearance was filed on beh

EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, ■. and requests this Court, pursuant to Florida Rule of Civil Procedure 1.230, for leave to intervene as a party in Mr. Epstein's criminal matter for the following reasons: 1. Applicant's intervention is in

, West Palm Beach, FL 33401. 09112/2019 LEOPOLD-KUVIN, PA 2925 PGA Boulevard Suite 200 Palm Be (561

efendant. CA 2008CF009381A>a MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, B.B. and requests this Court, pursuant to Florida Rule of Civil Procedure 1.230, for leave to intervene as a party in Mr. Epstein's criminal matter for the following reasons: 1. Applicant's intervention is in