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ree-standing action for injunctive relief or in conjunction with a tort action for, among other things, breach of fiduciary duty. See, M·, Saini v. International Game Technology, 434 F.Supp.2d 913, 924 (D.Nev. 2006)(court finds that company had shown likelihood of success in proving breach of implied covenant of good faith
ee infra. Therefore, an in camera hearing should occur to determine what objections and privileges must be raised before disclosure is made. U.S. v. Zolin, 491 U.S. 554, 575 (1989)(disclosing materials to the district court does not have the legal effect of 4 Case 9:08-cv-80119-KAM Document 559
ree-standing action for injunctive relief or in conjunction with a tort action for, among other things, breach of fiduciary duty. See, M·, Saini v. International Game Technology, 434 F.Supp.2d 913, 924 (D.Nev. 2006)(court finds that company had shown likelihood of success in proving breach of implied covenant of good faith
Therefore, an in camera hearing should occur to determine what objections and privileges must be raised before further disclosure is made. U.S. v. Zolin, 491 U.S. 554, 575 (1989)(disclosing materials 2 Because of the relief sought in this Rule 4 Appeal, Epstein's civil lawyers have not obtained a cop
e-standing action for injunctive relief or in conjunction with a tort action for, among other things, breach of fiduciary duty. agg, a g., Saini v. International Game Technology, 434 F.Supp.2d 913, 924 (D.Nev. 2006)(court finds that company had shown likelihood of success in proving breach of implied covenant of good faith
Therefore, an in camera hearing should occur to determine what objections and privileges must be raised before further disclosure is made. U.S. v. Zolin, 491 U.S. 554, 575 (1989)(disclosing materials to the district court does not have the legal effect of terminating a privilege thereby allowing par
Entities connected to both International Game Technology and Zolin

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Adam D. Horowitz
PERSONMermelstein & Horowitz
ORGANIZATIONIsidro Manuel Garcia
PERSONMichael J. Pike
PERSONBertine
PERSONJardines
PERSON
Alfredo Rodriguez
PERSONScott Lewis'
PERSONStandard Brands, Inc.
ORGANIZATIONZumpe
ORGANIZATIONFavalora
PERSONMaria Farmer
PERSON
Colorado
LOCATIONTara A. Finnigan
PERSONLynch
PERSON