Epstein Secrets

ED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARR A/JOHNSON Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 DEFENDANT'

e theory of the requestor's case, or to some significant aspect of the case); Ashemimry v. Ba Nafa, 847 So.2d 603 (Fla. 5th DCA 2003). In addition, Florida Rule of Civil Procedure 1.280(b)(3), does allow discovery of fact work product where the requesting party can show need and the inability to obtain the substantia

on the parties and upon the Court.'" Hufcor/Gulfstream, Inc. v. Homestead Concrete & Drainage, Inc., 831 So. 2d 767, 769 (Fla. 4th DCA 2002) (citing Johnson v. Johnson, 663 So. 2d 663, 664-65 (Fla. 2d DCA 1995)); Munoz Hnos., S.A. v. Editorial Televisa Intern., S.A., 121 So. 3d 100, 103 (Fla. 3d DCA 201

z, 785 So. 2d 589, 591 (Fla. 5th DCA 2001) ("[M]erely attaching an unswom document ... does not . . . satisfy the procedural strictures inherent in Florida Rule of Civil Procedure 1.510(e)."). Scarola and Edwards are veteran trial attorneys, are well aware of these Rules, and are more than familiar with the signific

the privilege log to be insufficient on its face and not in compliance with the requirements of Fla. R. Civ. P. 1.280(v)(5) and Tigg Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4'h DCA 2001). Although that Order was vacated without prejudice on August 17, 2012, the trial court still required a proper

ify them on his Exhibit List. Edwards has provided not a single reason why this Court should expedite its careful review and enforce the mandate of Florida Rule of Civil Procedure 1.440 (Petition for Writ of Mandamus) and determine if the severance of the interrelated and dependent actions should continue to one jur

found to be insufficient on its face and not-compliant with the requirements of Florida Rule of Civil Procedure 1.280(b)(5)7 and TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Edwards has claimed that none of the documents on the disc that were listed on his privilege log had ever been

ivilege log that this Court's predecessor, The Honorable David Crow, found to be insufficient on its face and not-compliant with the requirements of Florida Rule of Civil Procedure 1.280(b)(5)7 and TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Edwards has claimed that none of the documents on the dis

urring during the course of a judicial proceeding, if those acts bear some relation to the proceeding. Edwards urged the Court to fmd that Olson v. Johnson, 96] So. 2d 356 (Fla. 2d DCA 2007), is in conflict with Wolfe, thereby allowing the Court to fmd that the privilege does not apply. However, Olson

ntitled to fees and costs. H. ANALYSIS The requirements for a valid proposal for settlement are set forth in section 768.79, Florida Statutes, and Florida Rule of Civil Procedure 1.442. The offer of judgment statute and rule must be strictly construed, as they are in derogation of the common law rule that each party

ocument 19 Entered on FLSD Docket 02/27/2009 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08- 80993-CIV-MARRA/JOHNSON JANE DOE NO. 7, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. AMENDED COMPLAINT Plaintiff, Jane Doe No. 7 ("Jane" or "Jane Doe"), brings this Com

the court reasoned that the purpose of discovery is to eliminate the likelihood of surprise and to Insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1)• see also Surf Drugs. Inc.. v. Vermette 236 So.2d 108, 111 (Fla. 7 EFTA00175217 Case 9:09-cv-80656-KAM Document 5 Entere