Epstein Secrets

EDWARDS, ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 401 East Las Olas Boulevard Suite 1660 Fort Lauderdale, Florida 33394 On behalf of the Defendant: ROBERT D. CRITTON, JR., ESQUIRE BURMAN, CRITTON & LUTTIER 303 Banyan Boulevard, Suite 400 West Palm Beach, Florida 33401 On behalf of the Witness: BRUCE REINHART,

Correct. They're pilot logs, not night logs. There are other records we indicated are corporate records, and with those you have to deal with Mr. Critton. MR. CRITTON: However, with the proviso, too, Case 9:08-cv-80119-KAM Document 402 Entered on FLSD Docket 11/09/2009 Page 18 of 26 I I I I

ea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). . .. Cou1is have long held that ' [ w]hile the standard of relevancy [in discovery] is a liberal one, it is

tating and belief that the communications to Mr. Epstein from his attorneys and staff, work product privileges. See Exhibit B; see also Affidavit of Robert D. Critton, Jr. attached as Exhibit D. 4. Mr. Cowles did not know, nor did he have any knowledge of, Mr. Epstein prior to his employment with Mr. Goldberger. See

ea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Indeed the 2000 Amendment to Rule 26 has effectively limited the scope of discoverable information to those

ed on the following Service List in the manner specified by CM/ECF on this 29th day of March 2009. Respectfully submitted, By: s/Michael J. Pike ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLE

udge Linnea Johnson noted in her October 28, 2009 Omnibus Order,2 "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (I Ith Cir. 1992) .... Courts have long held that '[w]hile the standard of relevancy [in discovery] is a liberal one, it is not

suant to Mag. J. Rule 4, S.D. Fla. for the reasons set out above; f. for such other and further relief as this Court deems just and proper. By: ROBERT D. CRITTON, JR., ESQ. Florida Bar #224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoi

imited the scope of disclosure or discovery to certain matters." :_While the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Courts have long held that while the standard of relevancy in discovery is a liberal one, it is not so libera