Epstein Secrets

asonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d 1251, 1255 (11th Cir. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were fact

ardless of the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 EFTA00205046 Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/201

asonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d 1251, 1255 (11th Cir. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were fact

ardless of the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 EFTA00205077 Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/201

sonable opportunity for further investigation or discovery. Fed. R. Civ. P. I1(b). Rule 1 1 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu

ardless of the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (111h Cir. 2007). EFTA00230005 • • • Case 9:08-cv-80736-KAM Document 79.1 Entered on FLSD Docket 05/03/

reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu

egardless of the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson' Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (111h Cir. 2007). 3 08-80736-CV-MARRA 000759 EFTA00230583 • • • Case 9:08-cv-80736-KAM Document 79.1