Epstein Secrets

ove, and that the Court grant such other and further relief as deemed necessary and proper. Respectfully submitted, s/Christopher E. Knight Lilly Ann Sanchez Fla. Bar No. 195677 Christopher E. Knight Fla. Bar No. 607363 Helaine S. Goodner Fla. Bar No. 462111 FOWLER WHITE BURNETT P.A. Espirito Santo

proof of service from Mr. Marsigliano attesting that he left M.J.'s complaint with the caretaker at Epstein's residence or usual place of abode." (D.E. 15 at p. II). This assertion is false. Defendant has never admitted that the proof of service states that Mr. Marsigliano left the Summons and Com

copy of her complaint and other documents with someone at the home", which is all that Plaintiff alleges, or whether Mr. Epstein had actual notice (D.E. 15 at 12), but, rather, whether the suit papers were left with "someone of suitable age and discretion who resides" at 9 East 71s' Street, New York.

mputer and cited by Edwards inn 16-18; correspondence between the U.S. Attorney and Jay Leflcowitz, Esq. (Exs. C and D and 9fq 6, 20, 25) and Lilly Ann Sanchez, Esq. (Ex. L andl 28); a book receipt (Ex. I and 1 22), message pads (Ex. A. 1 24) and a property receipt (Ex. O and 1 34) ; correspondence between

asked solely to poison the wel1.6 The Court recently sustained Plaintiffs objections to discovery requests geared solely to alleged sexual activity (D.E. 148, 149, and 150). Accordingly, the sword and shield doctrine does not apply to the illegitimate and irrelevant questions which Plaintiff declined

s or ESI. 5. This protective order is not intended to nor does it apply to any person or party not explicitly named herein. Submitted by: Lilly Ann Sanchez, FBN 195677 Christopher E. Knight, FBN 607363 Joseph L. Ackerman, Jr., FBN 235954 Rodney J. Janis, FBN 647896 FOWLER WHITE BURNETT P.A. 901 Phil

18, 2010 oral ruling granting Trustee's Motion for Expedited Relief Seeking a Protective Order and Approving Proposed Document Production Protocol ( D.E. #617), hereby agree to and request Court approval of the following stipulation: It is expected that, to facilitate the sharing of RRA's information

Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert

vilege log with its objections annotated (D.E. 224-1); (2) a motion to compel production of documents that are not privileged, numbering eight pages D.E. 225; (3) a twenty-four page, single-spaced affidavit of petitioners' counsel, addressing the EFTA00179785 Case 9:08-cv-80736-KAM Document 230 Ent