Epstein Secrets

. Here, Plaintiff has not met her burden establishing exceptional circumstances to preclude Epstein from attending her deposition. See Ferrigno v. Yoder, 495 so.2d 886, 887-888 Case 9:08-cv-80119-KAM Document 326 Entered on FLSD Docket 09/24/2009 Page 7 of 13 Page 7 (Fla. 2d DCA 1986)(the ru

t met the exceptional burden of proving to this court that Epstein should be excluded from her deposition. Plaintiff adopts and incorporates all of Jane Doe 2-S's argument with only one additional argument (i.e., that if this court allows Epstein to attend Jane Doe's deposition it would violate the right o

ending the case in the normal course of conducting discovery and filing motions would not be a breach? (Ex. "A," p.30). Mr. Horowitz - counsel for Jane Does 2-7: Subject to your rulings, of course, yes. (Ex. "A," p.30). *** The Court: But you're not taking the position that other than possibly doing s

. Here, Plaintiff has not met her burden establishing exceptional circumstances to preclude Epstein from attending her deposition. See Ferrigno v. Yoder, 495 so.2d 886, 887-888 (Fla. 2d DCA 1986)(the rules do not contemplate use as a means ofby which one party may gain a tactical advantage - the rig

D MEMORANDUM OF LAW Defendant, Jeffrey Epstein, ("Epstein") by and through his undersigned counsel, serves his Response In Opposition to Plaintiff Jane Doe No. 4's Motion for Sanctions and Motion for Protective Order, With Incorporated Memorandum of Law In support, Epstein states: I. Introduction 1.

17 Vasquez v. State, 777 So.2d 1200 (Fla. Dist. Ct. App. 2001) 21 Wainscot: v.. Dunn, 1994 WL 732093 (S.C. Ct. Common Pleas July 20, 1994) 29 Yoder v. Adriatic°, 459 So.2d 449 (Fla. Dist. Ct. App. 1984) 18 STATUTES CPLR 3101(a)(4) passim CPLR 3102(e) 11, 1 2 MI Civil Rights Law § 79-h pa

that Rush had waived sa applicable reporter's privilege by disclosing brief portions of the Epstein interview to third parties (Balin Aff. Ex. K (Jane Doe's Response in Opposition to Motion of Daily News, to Quash Subpoena), at 6-13) — the same exact waiver argument he makes here. The federal District