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fact that target letters and subpoenas were issued relating to certain financial offenses. Sse Lg., DEs 282 and 283 submitted in camera and U.S. v. Zolin, 491 U.S. 554 (1989Xdisclosing materials to the district court does not have the legal effect of terminating a privilege thereby allowing parties t
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 therein are incorporated
e, if this court rules that any of the information requested herein should be produced (e.g., Requests Numbers 12 and 13 (tax returns and passport — Jane Doe) and Request Number 1 (tax returns-Jane Doe 2-8)), it shall only do so after an in camera hearing allowing the documents to be reviewed and placed 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
. ProHac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Tara A. Finnigan, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-83
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
efender's office, Dave Brannon, Esq .. At or around that same time, Counsel for Jane Does 2-8 provided a copy of the book or journal to counsel for Jane Doe, Mr. Bradley Edwards. Upon learning of Jane Does 2-8's counsel and Jane Doe's counsel coming into possession of the journal or book in the face of
t fact that target letters and subpoenas were issued relating to certain financial offenses. See M·, DEs 282 and 283 submitted in camera and U.S. v. Zolin, 491 U.S. 554 ( 1989)( disclosing materials to the district court does not have the legal effect of terminating a privilege thereby allowing partie
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
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
or Jane Does 2-8 provided a copy of the book or journal to counsel for Jane Doe, Mr. Bradley Edwards. Upon learning of Jane Does 2-8's counsel and Jane Doe's counsel coming into possession of the journal or book in the face of a Rule 4 Appeal, the undersigned and those attorneys reached an agreement that
Entities connected to both Zolin and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONMaria Farmer
PERSONRobert D. Critton
PERSON
George W. Bush
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSON
Salt Lake City
LOCATIONScott Rothstein
PERSONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSONIsidro Manuel Garcia
PERSON
Jay Lefkowitz
PERSONStuart S. Mermelstein
PERSON