Epstein Secrets

ea 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 & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Indeed the 2000 Amendment to Rule 26 has effectively limited the scope of discoverable information to those

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

ea 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 & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). . .. Cou1is have long held that ' [ w]hile the standard of relevancy [in discovery] is a liberal one, it is

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

udge 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 Tobacco, 959 F.2d 1566, 1570 (I Ith Cir. 1992) .... Courts have long held that '[w]hile the standard of relevancy [in discovery] is a liberal one, it is not

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

mited the scope of disclosure or discovery to certain matters." 9. While the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Courts have long held that while the standard of relevancy in discovery is a liberal one, it is not so libera

DE 555) pursuant to Mag. J. Rule 4, S.D. Fla. for the reasons set out above; f. proper. for such other and s this Court deems just and on a ar MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service Case 9:08-cv-80119-KAM Document 560 Entered on FLSD Docket 06/10/2010 Page 10 of 11 I HER

imited the scope of disclosure or discovery to certain matters." :_While the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Courts have long held that while the standard of relevancy in discovery is a liberal one, it is not so libera

set out above; f. for such other and further relief as this Court deems just and proper. By: ROBERT D. CRITTON, JR., ESQ. Florida Bar #224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was being served this day on all counsel of r