Epstein Secrets

rivilege is very clearly defined in Florida Rule of Civil Procedure 1.280(b)(3). And, Your Honor, that is quoted in the response in opposition to Jeffrey Epstein's motion to overrule objections and compel answers to these questions. It is quoted in its entirety at page two of our response. And it says that a

urt is aware, the only thing pending at this point in time in the case is Mr. Edwards' claim of abuse of process malicious prosecution against Mr. Epstein. The abuse of process claim has been disposed of. It was successfully won on the summary judgment and is no longer an issue. So the only operativ

H COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv

f abuse of process malicious prosecution against Mr. Epstein. The abuse of process claim has been disposed o

that he alleges in a complaint, even if the question reveals a legal theory of his case. And the case that stands for that proposition, Judge, is Dunkin' Donuts versus Mary's Donuts, 206 F.R.D. District of Florida 2002. rationale supporting this 518 Southern And again, the was quoted by the Florida Sup

2015, the Government provided answers to some of the discovery requests. With regard to the discovery requests concerning information about one of Jeffrey Epstein's defense attorneys, Alan Dershowitz, the Government refused to provide any information, asserting that any information about Dershowitz was irrelevan

ent would either produce that information or produce an appropriate privilege log.' The victims believe that the discovery requests regarding one of Epstein's defense attorneys are reasonably calculated to lead to the discovery of admissible evidence, for all the reasons explained in this memorandum. Fo

ery requests concerning information about one of Jeffrey Epstein's defense attorneys, Alan Dershowitz, the

or discovery purposes is much broader than relevance for trial purposes." Adelman Boy Scouts of All!" 276 F.R.D. 681, 688 (S.D. Fla. 2011) (citing Dunkin' Donuts, Inc.., Mary's Donuts, Inc., No. 01-0392,2001 WL 34079319, *2 (S.D.Fla. Nov. 1, 2001) (emphases deleted)). This Court has previously explained the "

From: President To: Jeffrey Epstein <[email protected]> Subject: Re: Hello Date: Sun, 20 Jan 2013 17:25:35 +0000 You are kidding! But you know your birthday was listed on some ce

From: President To: Jeffrey Epstein <[email protected]> Subject: Re: Hello Date

From: President To: Jeffrey Epstein <[email protected]> Subject: Re: Hel

HHHHH!!!!!!!! On Sun, Jan 20, 2013 at 11:44 AM, President < > wrote: I know you will survive; and you don't have to join AARP do get a discount at Dunkin' Donuts. Let's both wait till 80. Have fun. Leon The information contained in this communication is confidential, may be attorney-client privileged, may

From: President < Sent: Sunday, January 20, 2013 4:45 PM To: Jeffrey epstein Subject: Hello I know you will survive; and you don't have to join AARP do get a discount at Dunkin' Donuts. Let's both wait till 80. Have fun. Le

< Sent: Sunday, January 20, 2013 4:45 PM To: Jeffrey epstein Subject: Hello I know you will survive

unday, January 20, 2013 4:45 PM To: Jeffrey epstein Subject: Hello I know you will survive; and you don't have to join AARP do get a discount at Dunkin' Donuts. Let's both wait till 80. Have fun. Leon <?xml version="1.0" encoding="UTF-8"?> <!DOCTYPE plist PUBLIC "-//Apple//DTD PLIST 1.0//EN" "http://www.

From: President < Sent: Sunday, January 20, 2013 4:45 PM To: Jeffrey epstein Subject: Hello I know you will survive; and you don't have to join AARP do get a discount at Dunkin' Donuts. Let's both wait till 80. Have fun. Le

< Sent: Sunday, January 20, 2013 4:45 PM To: Jeffrey epstein Subject: Hello I know you will survive

unday, January 20, 2013 4:45 PM To: Jeffrey epstein Subject: Hello I know you will survive; and you don't have to join AARP do get a discount at Dunkin' Donuts. Let's both wait till 80. Have fun. Leon <?xml version="1.0" encoding="UTF-8"?> <!DOCTYPE plist PUBLIC "-//Apple//DTD PLIST 1.0//EN" "http://www.