Epstein Secrets

e legal consequences of their actions. FN18. See General Motors Corp. v. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105, 11

ESQ. Florida Bar No. 22 :62 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BU

ttled that a Defendant may take the deposition of a party and/or a witness before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and Leve v. General Motors Corp., 43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2 and 3 commenced separate civil actions upon the filing of same against Jeffrey Epstein. Therefore,

FLSD Docket 04/17/2009 Page 7 of 7 Page 7 Respectfully subm' d, By: fie ROBRT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/84

s attorney. 12. The attorney-client privilege also extends to subordinates of a party's attorney. -- - - - - - ··- --·· -· -- . -- See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege

erence call that Mr. Cowles would not be deposed if Ms. Kellen was made available for her deposition, which she was in April, 2010. See Affidavit of Michael J. Pike attached as Exhibit F and 10/13/09 E-mail from Spencer Kuvin attached as Exhibit G. While counsel for Jane Doe did not confirm this agreement in wr

e legal consequences of their actions. FNl8. See General Motors Corp. v. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105, 11

SQ. Florida Bar No. 224 I 62 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BU

settled that a Defendant may take the deposition of a ma and/or a witty-cc before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and lave v. General Motors Corp., 43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2-7 commenced separate civil actions upon the filing of same against Jeffrey Epstein. Therefore, Def

08-cv-80119-KAM Document 79 Entered on FLSD Docket 04/17/2009 Page 7 of 7 Page 7 Respectfully sub By: ROBERT D. CRITTON, JR., ESQ. Milit 4162 MICHAEL J. PIKE, ESQ. ER & COLEMAN Phone Fax (Co-Couruel for Defendant Jeffrey Epstein) EFTA00722742 37 93dge 9:08-01301VRAIr•bocument 79-2 Entered on FLSD e

ts or representatives of a party's attorney. 12. The attorney-client privilege also extends to subordinates of a party's attorney. See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege

a conference call that Mr. Cowles would not be deposed if Ms. was made available for her deposition, which she was in April, 2010. See Affidavit of Michael J. Pike attached as Exhibit F and 10/13/09 E-mail from Spencer Kuvin attached as Exhibit G. While counsel for Jane Doe did not confirm this agreement in wr