Epstein Secrets

DATED this day of , 20 . Jack Scarola Florida Bar No.: 169440 Jack P. Hill Florida Bar No.: 0547808 Phone: Fax: Attorneys for Plaintiff(s) Shipley, P.A. EFTA00722714 v, Epstein, et al Case No. 50 2008CA025129=O(MB Al SDT Without Deposition Page3 CERTIFICATION OF RESPONSE TO SUBPOENA DUCE

urdensome and over- broad, but also constituted a fishing expedition un- related to the issues raised by the pleadings. In Allstate Insurance Co. v. Langston, 655 So.2d 91, 95 (Fla.1995), the supreme court held that certi- orari was available and should be used to quash an order "to the extent that it pe

hed list, this V day of February, 2009. Jack Scarola Florida Bar No.: 189440 Jack P. Hill Florida Bar No.: 0547808 Attorneys for Plaintiff(s) Shipley, P.A. EFTA00614441 A.C. v. Epstein, et al Case No. 50 2008CA025129XXXXMB Al Notice of Production from Non-Party Page 3 COUNSEL LIST sissi At

urdensome and over- broad, but also constituted a fishing expedition un- related to the issues raised by the pleadings. In Allstate Insurance Co. v. Langston, 655 So.2d 91, 95 (Fla.1995), the supreme court held that certi- orari was available and should be used to quash an order "to the extent that it pe

to protect a non-party from discovery that would result in “annoyance, embarrassment, oppression or undue burden or expense...” Al/state Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 2003) (Florida Supreme Court overturning denial of protective order and holding that “[d]iscovery of certain kinds of inform

.com WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 Counsel for Defendant Alan Dershowitz Jack Scarola SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. [email protected] 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409-6601 Attorney for Plaintiffs 14 HOUSE_OVERSIGHT_015612 --- PAGE BR