3
Shared Docs
2
Same-Page
3 / 3
Mentions
r. 1983) 7 Drown & Williamson Tobacco Coro. v. Wigand, No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 28, 1996) 18 Bruno v. Stillman. Inc. v. Globe Newspaper Co. 633 F.2d 583 (1st Cir. 1980) 4, 5 Cablevision Systems Corp. v. DePalma, No. CV-87-3528 (JLC), 1989 WL 8165 (E.D.N.Y. Jan. 17. 1989) 7 Chick-Fil
eral law are "identical" to those under the applicable New York statute.— See Persky, supra. 2002 WL 31769704, at *3 (McKenna. J.). " Notably. Mr. Fisten claims he "wrote up a report memorializing what Rush had told me" shortly after his conversation with Mr. Rush (Fisten Aft*" I I) but chooses not to
r. 1983) 7 Drown & Williamson Tobacco Coro. v. Wigand, No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 28, 1996) 18 Bruno v. Stillman. Inc. v. Globe Newspaper Co. 633 F.2d 583 (1st Cir. 1980) 4, 5 Cablevision Systems Corp. v. DePalma, No. CV-87-3528 (JLC), 1989 WL 8165 (E.D.N.Y. Jan. 17. 1989) 7 Chick-Fil
eral law are "identical" to those under the applicable New York statute.— See Persky. supra. 2002 WL 31769704, at *3 (McKenna. J.). " Notably. Mr. Fisten claims he "wrote up a report memorializing what Rush had told me" shortly after his conversation with Mr. Rush (Fisten Aft*" I I) but chooses not to
ther harassing actions against Jane Doe also followed. See Motion for Contempt filed by Edwards in Jane Doe v. Epstein detailing the event, including Fisten Affidavit attached to Motion, Composite Exhibit “RR.” Epstein Settlement of Civil Claims Against Him for Sexual Abuse of Children 84. The civil case
Page: HOUSE_OVERSIGHT_013354 →plead a claim for punitive damages, the claimant must show a “reasonable basis” for the recovery of such damages. See Fla.R.Civ-P. 1.190(f); see also Globe Newspaper Co. v. King, 658 So.2d 518, 520 (Fla. 1995). The showing required to amend is minimal. As stated in State of Wis. Inv. v. Plantation Square Assoc., 761 F
Page: HOUSE_OVERSIGHT_013396 →Entities connected to both Globe Newspaper Co. and Michael Fisten

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSONJane Doe
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONJack Scarola
PERSON
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
Paul Cassell
PERSON
Marc Rich
PERSONFlorida Bar
ORGANIZATION
New York Daily News
ORGANIZATION
the United States District Court
ORGANIZATION