Epstein Secrets

the information requested is neither relevant F to any pending claim or defense nor will it lead to the discovery of admissible evidence," citing Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 13. As illustrated above, the questions are simply not germane to any pending '--.. claim

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

7 of 11 infonnation requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence," citing Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 10. Accordingly, consistent with counsels' agreement noted above, a protective order shou

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

that the information requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence " chin Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 940. Accordingly, consistent with counsels' agreement noted above, a protective order shou

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