Epstein Secrets

te 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidrogarcia©bellsouth.net Counsel .for:Plaintiff in Related Case No. 08- 80469 ' Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 riosefsb

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

record, to be definitive, in that, we are not trying the other claims that may have been represented by other attorneys -- like Mr. Scarola, Mr. Josefsberg -- because they would be not only irrelevant, they would be very prejudicial to my client receiving a fair trial. THE COURT: Mr. Scarola. MR. SC

VE ORDER AND IN LIMINE OF UNRELATED SETTLEMENTS Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), moves for a protective order pursuant to Florida Rule of Civil Procedure 1.280(c) on the production and disclosure of any additional confidential settlement agreements and amounts and moves in limine pursuant to

efsberg et al City National Bank Building 25 W Flagler Street Suite 800 Miami FL 33130-1780 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Robert C. Josefsberg Podhurst Orseck Josefsberg et al City National Bank Building 25 W Flagler Street Suite 800 Miami FL 33130-1780 Fax: Email: LEAD ATTORNEY ATTOR

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

hildren who are also not parties in appellate proceedings. *390 Marsha B. Elsa. Miami; Cynthia L. Greene, Miami, for appellant. Podhurst, Orseck, Josefsberg, Eaton, Meadow, Olin, & Perwin, and Joel S. Perwin, Miami; Bar- ranco, Kircher, Vogelsang & Boldt, and Kimberly L. Boldt, Miami, for appellee. Bef

TEIN, JEFFREY E, Defendant. 1VIOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, B.B. and requests this Court, pursuant to Florida Rule of Civil Procedure 1.230, for leave to intervene as a party in Mr. Epstein's criminal matter for the following reasons: 1. Applicant's intervention is in

ildren who are also not parties in appellate proceedings. *390 Marsha B. Elser, Miami; Cynthia L. Greene, Miami, for appellant. Podhurst, Orseck, Josefsberg, Eaton, Meadow, Olin, & Perwin, and Joel S. Pcrwin, Miami; Bar- ranco, Kircher, Vogelsang & Boldt, and Kimberly L. Boldt, Miami, for appellee. Bef

EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, M. and requests this Court, pursuant to Florida Rule of Civil Procedure 1.230, for leave to intervene as a party in Mr. Epstein's criminal matter for the following reasons: 1. Applicant's intervention is in

ildren who are also not parties in appellate proceedings. •390 Marsha B. Elser. Miami; Cynthia L. Greene, Miami, for appellant. Podhurst, Orseck, Josefsberg, Eaton, Meadow, Olin, & Perwin, and Joel S. Perwin, Miami; Bar- ranco, Kircher, Vogelsang & BoIdt, and Kimberly L. Bolds, Miami, for appellee. Bef

EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, ■. and requests this Court, pursuant to Florida Rule of Civil Procedure 1.230, for leave to intervene as a party in Mr. Epstein's criminal matter for the following reasons: 1. Applicant's intervention is in