Epstein Secrets

time in the schedule to depose Mr. Rothstein. The deposition of Scott Rothstein was taken in the bankruptcy proceeding of Rothstein, Rosenfeldt and Adler ("RRA"), but not completed, from December 12, 2011 through December 7 EFTA00808032 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXM

7 So. 2d 355, 357 (Ha. 1s' DCA 1996); Albelo v. Southern Bell, 682 So.2d 1126, 1129 (Ha. 4'h DCA 1996). Finally, summary judgments are not favored. O'Connor v. Marston, 717 So. 2d 82 (Ha. 5th DCA, 1998). It is also necessary for the movant to authenticate the undisputed facts upon which its claim for s

r. 1975)). The parole evidence rule serves to protect a party to a written contract from infirmity of memory, perjury, or the death of witnesses. Adler, 721 F.Supp. at 476. 1181 We have examined the November 1984 contract and find it to be a complete integration of the parties' agreement. See con

depositions, this Court has the power and duty under Fed. R. Civ. P. 26(c) to determine the most appropriate location for each deposition. See e.g., O'Connor.. Trans Union Corp., 1998 U.S. Dist. LEXIS 6774 (E.D. Pa. May 11, 1998). This Court has previously determined "that as a general rule, if a deponen

overy motion. The facts underlying that action are briefly as follows: Scott Rothstein was the managing partner and CEO of Rothstein, Rosenfeldt and Adler ('RRA"), a 70-lawyer firm in Fort Lauderdale, Florida. Balin Aft Ex. A, Ex. 1 ("Rothstein Information") ¶¶ 1-2; id., Ex. 2 (Amended Complaint for D

4, 15, 16 McGarry v. University ojSan Diego, 64 Cal. Rptr. 3d 467 (Cal. Ct. App. 2007) 28, 29 iii D14'71584534593 3970112-000042 EFTA00596452 O'Connor v. Donaldson, 422 U.S. 563 (1975) 13 O'Neill v. Oakgrove Coast. Inc., 71 1.2d 521, 528 ad 1 (1988) 1, 2, 22 People ex reL Scott v. Silverstein