Epstein Secrets

ld this court order production of same after an in camera inspection) must be redacted to secure the names of unsuspecting third-parties. Moreover, Michael Fisten (formerly an employee of RRA and now an employee/independent contractor of Mr. Edwards' firm) acted, upon information and belief, as a broker or mid

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

red private investigators to perform investigative work in anticipation and furtherance of litigation. 8. Several private investigators, including Michael Fisten and Richard Fandry, were hired by RRA to perform investigative work on the L.M. case, in anticipation and furtherance of litigation. 9. As has be

COTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant. MOTION FOR PROTECTIVE ORDER L.M., pursuant to Florida Rule of Civil Procedure 1.280(c), hereby files this Motion for Protective Order to prevent the depositions of any private investigators who are working on or hav

t opportunities in any claim or litigation against Jeffrey Epstein: a) Scott Rothstein b) Russell Adler c) William Berger d) Bradley Edwards e) Michael Fisten f) Kenneth Jenne g) David Baden h) Deborah Villegas i) Andrew Barnett j) Patrick k) Richard (Rick) Fandrey I) Christina Kitterman 2. Any and

CA040800XXXXMB AG RE-NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM TO: All Counsel of Record PLEASE TAKE NOTICE that the undersigned, pursuant to Florida Rule of Civil Procedure 1.310(b)(4), will take the video deposition of: NAME AJ DiScala DATE AND TIME PLACE Wednesday May 25, 2011 10:30 a.m. Dewey I,eBoe

name that topic?" Mr. Scarola: "Work product, instruct you not to answer." It goes on. "Who" -- at the bottom of page seven. "Who other than Mr. Fisten from an investigator -- from an internal investigator and RRA employee worked on doing investigations on the Epstein files?" Mr. Scarola: "Same o

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 way, that the court should grant us the access to the information. That's in Florida Rule of Civil Procedure 1.280(b)(4), and in Genovese versus Provident Life 74 So.3d 1064 Florida Supreme Court 2011. It's also established, Judge, under the la