4
Shared Docs
4
Same-Page
4 / 4
Mentions
ested documents, as to their authenticity, and as to the defendant's selection of them as meeting the requests for production. ate United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly auth
ry, Ins., 2008 WL 3895918 (S.D. Ha. 2009)(unless liability for punitive damages is established at trial, the discovery sought is not relevant). In Gallina, the court held that in light of the proprietary of the financial worth information sought, and the statutory protections against discovery of such
94-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 2 of 10 3 Fisher v. United States, 425 U.S. 391, 410 (1976) and United States v. Hubbell, 530 U.S. 27, 35- 36 (2000). As noted by the Magistrate Judge, “Defendant cannot reasonably and in good faith argue that in producing these documen
m of money which, according to his financial ability, will hurt, but not 3 Defendant’s reliance on Gallina v. Commerce and Industry Ins., 2008 WL 3895918 (M.D. Fla. 2008) is misplaced. Gallina is an insurance bad faith case and does not involve a claim o
ested documents, as to their authenticity, and as to the defendant's selection of them as meeting the requests for production. See United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly auth
ent 545 Entered on FLSD Docket 05/12/2010 Page 26 of 37 Doe v. Epstein 08-CV80119 Page No. 26 also Fed.R.Civ.P. 26(b)(l) and Fla. Stat. 768.72; Gallina v. Commerce And Industry, Ins., 2008 WL 3895918 (S.D. Fla. 2009)(unless liability for punitive damages is established at trial, the discovery sough
es, 425 U.S. 391, 410 (1976) and United States v. Hubbell, 530 U.S. 27, 35- 36 (2000). As noted by the Mag
3 Defendant’s reliance on Gallina v. Commerce and Industry Ins., 2008 WL 3895918 (M
Entities connected to both Hubbell and Gallina

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
United States
LOCATION
Adam D. Horowitz
PERSON
Jay Lefkowitz
PERSONMichael J. Pike
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Edwin
PERSONRobert C. Josefsberg
PERSONTurley
PERSONKatherine W. Ezell
PERSONIsidro Manuel Garcia
PERSONStuart S. Mermelstein
PERSON
Kenneth Marra
PERSONSecond Circuit
ORGANIZATIONMermelstein & Horowitz
ORGANIZATIONJack Patrick Hill
PERSON
Alan Dershowitz
PERSON