Epstein Secrets

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

des Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. §2255, one of the principal causes of action in the Jane Doe cases. This opinion work product should not be disclosed when it was incorporated into heartland plea negotiations that are accorded protection und

e Life Assurance Society of the United States v. Daisy Worldwide, Inc., 702 So. 2d 263 (Fla. 3d DCA 1997). Plaintiff ha

EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE, MOTION TO COMPEL RESPONSE TO PLAINTIFF'S REQUES

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

ocket entries. Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 4 of 37 Doe v. Epstein 08-CV80119 Page No. 4 (a) Jane Doe Plaintiff, Jane Doe's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth t