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hrough a free-standing action for injunctive relief or in conjunction with a tort action for, among other things, breach of fiduciary duty. See, M·, Saini v. International Game Technology, 434 F.Supp.2d 913, 924 (D.Nev. 2006)(court finds that company had shown likelihood of success in proving breach o
ee infra. Therefore, an in camera hearing should occur to determine what objections and privileges must be raised before disclosure is made. U.S. v. Zolin, 491 U.S. 554, 575 (1989)(disclosing materials to the district court does not have the legal effect of 4 Case 9:08-cv-80119-KAM Document 559
hrough a free-standing action for injunctive relief or in conjunction with a tort action for, among other things, breach of fiduciary duty. See, M·, Saini v. International Game Technology, 434 F.Supp.2d 913, 924 (D.Nev. 2006)(court finds that company had shown likelihood of success in proving breach o
Therefore, an in camera hearing should occur to determine what objections and privileges must be raised before further disclosure is made. U.S. v. Zolin, 491 U.S. 554, 575 (1989)(disclosing materials 2 Because of the relief sought in this Rule 4 Appeal, Epstein's civil lawyers have not obtained a cop
ough a free-standing action for injunctive relief or in conjunction with a tort action for, among other things, breach of fiduciary duty. agg, a g., Saini v. International Game Technology, 434 F.Supp.2d 913, 924 (D.Nev. 2006)(court finds that company had shown likelihood of success in proving breach o
Therefore, an in camera hearing should occur to determine what objections and privileges must be raised before further disclosure is made. U.S. v. Zolin, 491 U.S. 554, 575 (1989)(disclosing materials to the district court does not have the legal effect of terminating a privilege thereby allowing par
Entities connected to both Saini and Zolin

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Adam D. Horowitz
PERSONMermelstein & Horowitz
ORGANIZATIONIsidro Manuel Garcia
PERSONMichael J. Pike
PERSON
Alfredo Rodriguez
PERSONZumpe
ORGANIZATIONStandard Brands, Inc.
ORGANIZATIONBertine
PERSON
Salt Lake City
LOCATIONInternational Game Technology
ORGANIZATIONLynch
PERSONMaria Farmer
PERSONFavalora
PERSONScott Lewis'
PERSON
Colorado
LOCATION