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o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment s
e Life Assurance Society of the United States v. Daisy Worldwide, Inc., 702 So. 2d 263 (Fla. 3d DCA 1997). Plaintiff ha
sult in criminal prosecution. See generally Hoffman v United States, 341 U.S. at 486; United States v. Hubbell, 530 U.S. at 36 and United States v. Apfelbaum, 445 U.S. at 128. The Court's order seems to hone in on the "required records" exception for the proposition that, as a matter of law, Epstein's pe
D Docket 02/26/2010 Page 22 of 24 Doe v. Epstein 08-CVS0! !9 Page No. 22 2005); see also Eguitable Life Assurance Society of the United States v. Daisy Worldwide, Inc., 702 So. 2d 263 (Fla. 3d DCA 1997). Plaintiff has failed to meet this burden and, in doing so, has also failed to show any substantial need for the
sult in criminal prosecution. See generally Hoffman v United States, 341 U.S. at 486; United States v. Hubbell, 530 U.S. at 36 and United States v. Apfelbaum, 445 U.S. at 128. The Court's order seems to hone in on the "required records" exception for the proposition that, as a matter of law, Epstein's pe
ction. See Young Circle Garage, LLC. v. Koppel, 916 So. 2d 22 (Fla. 4th DCA 2005); see also Equitable Life Assurance Society of the United States v. Daisy Worldwide, Inc., 702 So. 2d 263 (Fla. 3d DCA 1997). Plaintiff has failed to meet this burden and, in doing so, has also failed to show any substantial need for the
Entities connected to both Apfelbaum and Daisy Worldwide, Inc.

Jeffrey Epstein
PERSONHubbell
PERSON
Jay Lefkowitz
PERSONJane Doe
PERSON
Edwin
PERSONTurley
PERSON
United States
LOCATIONJack Goldberger
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Rudy Giuliani
PERSONKatherine W. Ezell
PERSON
Salt Lake City
LOCATIONRobert C. Josefsberg
PERSONIsidro Manuel Garcia
PERSONGlanzer
PERSONSpencer Kuvin
PERSONMermelstein & Horowitz
ORGANIZATION