Epstein Secrets

r conversations with hei· supervising partner as the questions invaded the attorney-client privilege). 14. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi

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

d beyond September of 2005. Therefore whatever information Mr. Zinoview may have, postdates that time. 5. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi

ite 400 West Palm Be , FL 33401 (561) 842- (561) 84 By: __;,,_,___,~:1---___:...p_ .. '1-:-q_}-__ R e . Critton, Jr. ~( F orida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) Case 9:08-cv-80119-KAM Document 402 Entered on FLSD Docket 11/09/2009 Page 17

opriate and irrelevant and not reasonably calculated to lead to the discovery of admissible evidence." 24. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order,2 "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson

Y EPSTEIN, respectfully requests the Court deny Jane Doe's Motion (DE #486) and grant any additional relief the Court deems just and proper. By: s/Michael J. Pike ROBERT D. CRITTON, JR., ESQ. Florida Bar #224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true

er conversations with her supervising partner as the questions invaded the attorney-client privilege). 14. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. & William

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