Epstein Secrets

n, 466 So.2d 1188, 1192 (Fla. 4th DCA 1985); and Doherty v. John Doe No. 22, 957 So.2d 1267 (4th DCA 2007)

EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE, MOTION TO COMPEL RESPONSE TO PLAINTIFF'S REQUES

." See endnote 2 for full text of §39.204, Fla. Stat.2 (,-r's Motion, p. 8-9). See Carson v. Jackson, 466 So.2d 1188, 1192 (Fla. 4th DCA 1985); and Doherty v. John Doe No. 22, 957 So.2d 1267 (4th DCA 2007). A reading of these cases establishes that §39.204 does not provide Plaintiff with a carte blanc

l recording or other audio or video depiction or image of the Palm Beach Residence. Request No. 8. All documents referring or relating to Plaintiff Jane Doe No. 2, including without limitation, web pages, social networking site pages, correspondence, videotapes and audiotapes. Request No. 9. (Not at is

ourt is required to hold an in camera inspection of documents to determine, as to each document, whether Florida Statute §39.204 is applicable. See Doherty v. John Doe No. 22, 957 So.2d 1267 (Fla. 4th DCA 2007). Plaintiff agrees that such an in camera inspection would be appropriate to evaluate whethe

F FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPS

04." See endnote 2 for full text of §39.204, Fla. Stat.2 (¶'s Motion, p. 8-9). See Carson v. Jackson, 466 So.2d 1188, 1192 (Fla. 4th DCA 1985); and Doherty v. John Doe No. 22, 957 So.2d 1267 (4th DCA 2007). A reading of these cases establishes that §39.204 does not provide Plaintiff with a carte blanche

ing these protections meaningless in attempting EFTA00222075 Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 2 of 37 Jane Doe No. 2 v. Epstein Page 2 to assert and argue the factual basis for the additional objections and privileges. See part ILA. herein. I. Defendant E