Epstein Secrets

South, Suite 1400, West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suitk,Q0 est Palm Beach, FL 33401. LEOPOLD—KUVIN, P.A. 2925 PGA Boulevard Suite 200 alm Beach Garde i 410 T. KUVIN, Esq. ar No.: 089737 Page 3of 3 EFTA00180827 Page 2 of I I Westla

lude the moving party's likelihood of success on the merits, and the likelihood of harm should a stay not be granted. See Stale tuc rel. Price v. McCord, 380 So.2d 1037 (Fla.1980). During the course of the trial court pro- ceedings, the children had been spending the summer with the Former Husband

e? 18 A. Yes. I guess you could say that. 19 Q. And who else was there? 20 A. My Aunt fia 21 Q. And what was that meeting about? 22 MR. LEOPOLD: Objection. That calls for 23 attorney/client privilege. 24 BY MR. TEIN: 25 Q. What discussions did you have with Ph. Fax. 1655 Palm Beach

granted, and the remedial quality of any such harm. See Perez v. Perez, 769 M. 2d 389, 391 n.4 (Fla. 3d DCA 1999); see also State ex rel. Price v. McCord, 380 E. 2d 1037, 1038 n.3 (Fla. 1980). The trial court agreed that Mr. Epstein had established irreparable harm (A-17:16), denied a 7 EFTA00231139

nue South, Suite 1400, West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suit est Palm Beach, FL 33401. LEOPOLD—KM/TN, P.A. 2925 PGA Boulevard Suite 200 ens, FL 33410 (facsimile) T. KUV1N, Esq. ar No.: 089737 Page 3of 3 EFTA00231327 Page 2 of I I Wds

clude the moving party's likelihood of success on the merits, and the likelihood of harm should a stay not be granted. See State ex rel. Price v. McCord, 380 1.2d 1037 (Fla.1980). During the course of the trial court pro- ceedings, the children had been spending the summer with the Former Husband p

9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 85 of 100 sor & Associates Repanimp, and Transaipdan. inc. Page 59 1 MR. LEOPOLD: I'll certify it. 2 CERTIFIED QUESTION 3 She's answered that question. She's explained it five 4 tines already. The fact that Counsel doesn't

granted, and the remedial quality of any such harm. See Perez v. Perez, 769 So. 2d 389, 391 n.4 (Fla. 3d DCA 1999); see also State ex rel. Price v. McCord, 380 So. 2d 1037, 1038 n.3 (Fla. 1980). The trial court agreed that Mr. Epstein had established irreparable harm (A-17:16), denied a 7 EFTA0023225