Epstein Secrets

3, 2014) (internal quotation marks omitted)). Moreover, at least one New York court has found that British privilege law is "apparently similar" to New York's. Aetna Cas. & Sur. Co. v. Certain Underwriters at Lloyd's London, 4 "Where there is no attorney involved in the communication ..., there can be no

uffre v. Maxwell, No. 15 CIV. 7433 (RWS), 2016 WL 831949, at *2 n.2 (S.D.N.Y. Feb. 29, 2016) ("Because New York has the most significant interest, New York law applies."). The potential litigation for which Defendant sought Barden's advice never came to frOition and no • pending issues in or relating

.Y.C.P.L.R. S 4503(a)(1). The privilege only applies to attorney-client communications "primarily or predominately of a legal character." Rossi v. Blue Cross & Blue Shield of Greater N.Y., 13 EFTA_R1_00011989 EFTA01734199 Case 1:15-cv-07433-RWS Document 135 Filed 05/02/16 Page 14 of 37 73 N.Y.2d 588, 594, 542 N.Y

elief upon by the Court in reaching its conclusion may suffice for natural persons, the Court is asked to reconsider that decision in recognition of New York's specific instructions for service of process on corporations. The affidavit of service of Plaintiff's process server states that he delivered a copy

ed: C. The Court Will Not Dismiss the Matter Based on Fancelli's Defense of 3 See Neitzke v. Williams, 490 U.S. 319, 326-27 (1989) See Leuthner v. Blue Cross & Blue Shield of Northeastern Pa., 454 F.3d 120 (3d Cir. 2006)(affirming dismissal under Rule 12(6)(6) for lack of statutory standing). 3 EFTA00300055 Release

hat the whole of this dispute blossoms from an agreement made in New York between Plaintiff Epstein (wherever he was residing in 2005) and Molyneux (New York), then an agreement between Molyneux and Fancelli (New York). It is respectfully submitted that the law of the State of New York will be operative t

state that Plaintiff L.S.J., LLC, is the owner of Little St. James Island. See Neitzke v. Williams, 490 U.S. 319, 326-27 (1989) 2 See Leuthner v. Blue Cross & Blue Shield of Northeastern Pa. 454 17.3d 120 (3d Cir. 2006)(affirming dismissal under Rule 12(b)(6) for lack of statutory standing). EFTA00310015 DEFENDANT'