Document Mentions (4 shared documents)

EFTA00808026

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ce and documents between Epstein's counsel and Federal prosecutors violates an Order entered in Jane Doe No. 2. v. Epstein, Case No. 08-80893-Marra/Johnson on January 5, 2011. (See D.E. 226) (Ex. A attached hereto). Pursuant to that Order, Edwards is required to seek leave of court before filing or mak

A040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ revealing relevant information in pretrial discovery." (emphasis added). The Fourth District explained in Brancaccio that the "Supreme Court has disapproved of procedures which require a party to surrender one constitutional right in order

EFTA00808658

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specific documents withheld with enough detail to facilitate the evaluation of and challenges to the privileges asserted therein. TIG Ins. Cap. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001); Abbott Laboratories v. Alpha Therapeutic Corp., No. 97-C-1292, 2000 WL 1863543 (N.D. III. Dec. 14, 2000). Had t

dwards, 4'h DCA Case No. 4D18-0787. (Composite Exhibit C.) CONCLUSION Epstein's general references in pre-trial filings with this Court and in the Fourth District Court of Appeal to the 47 exhibits in question are fully compliant with the Court's rulings at the March 8, 2018 hearing. Epstein has not dissemina

EFTA00606510

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ts with regards to the g issue whether the litigation privilege bars a 9 malicious prosecution claim. And I have cited to 10 the case Olson vs. Johnson, 961 Sold. 356, the 11 Second DCA's opinion in 2007, after both Levin and 12 Echevarria. And it holds that malicious 13 prosecution claims are

efore them 3 because it had already been determined that the 4 litigation privilege applied to the abuse of 5 process in both the Third and the Fourth District 6 Courts of Appeal. That's admitted by 7 the counterclaim in their motion in opposition. g I wanted to speak about this idea that the 9 worst