Epstein Secrets

April ., 2009: Theodore J. Leopold, Esq. Jack Alan Goldberger, Esq. Spencer T. Kuvin, Esq. Atterbu

urdensome and over- broad, but also constituted a fishing expedition un- related to the issues raised by the pleadings. In Allstate Insurance Co. v. Langston, 655 So.2d 91, 95 (Fla.1995), the supreme court held that certi- orari was available and should be used to quash an order "to the extent that it pe

eopold- Kuvin, P.A., Counsel for Plaintiff; Jack Alan Goldberger, Esq., Atterbury Goldberger & Weiss,

urdensome and over- broad, but also constituted a fishing expedition un- related to the issues raised by the pleadings. In Allstate Insurance Co. v. Langston, 655 So.2d 91, 95 (Fla.1995), the supreme court held that certi- orari was available and should be used to quash an order "to the extent that it pe

te 200, Palm Beach Gardens, Florida 33410; Jack Alan Goldberger, Esquire, Atterbury Goldberger & Weis

or will lead to the discovery of relevant information, a trial court has discretion to deny the irrelevant discovery. Allstate Insurance Company v. Langston 655 So. 2d 91, 95 (Fla. 1995): Residence Inn by Marriott v. Cecile Resort, Ltd. 822 So. 2d 548, 550 (Fla. 5th DCA 2002) (agreeing that carte blanch

truck robberies, murdered Jewish talk show host Alan Berg, and were building up their army to overthro

FBI was involved in the investigation through the Joint Terrorism Task Force alongside the NYPD. WABC (ABC-7) (11/20, Katersky) and Hoodline (11/20, Langston) also reported on the story. Venezuelan Migrant Gang Tren de Aragua Now Operating in 16 States Fox News (11/20, Dorgan) reported that the Venezuel

Avenue, Suite 2, Fort Lauderdale, FL 33301; Jack Alan Goldberger, Atterbury, Goldberger & Weiss, P.A.,

ated to lead to the discovery of admissible evidence in the case in which the discovery is sought. Fla. R. Civ. P. 1.280(b)(1); Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). 10. "Pretrial discovery was implemented to simplify the issues in a case, to eliminate the element of surprise, t

Counsel for Defendant Jeffrey Epstein) and Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement a

Counsel for Defendant J6ffrey Epstein) and Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 M. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement an

Counsel for Defendant Jeffrey Epstein) and Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement a

ppropriate 13:1,6 certainly 12:8 13:25 15:11 4:22 bench 12:10 content al argue 11:11 certify 15:1 2:3,6 5:4 8:7 Berger 16:4 contest ALAN argument 2:10 3:10,10 chance 8:10 2:2 9:9 14:8 3:20,21,22 8:7 copy EFTA00233762 Proceedings June 10, 2009 2 6:14,23 correctly 8:15 c

l injury to the petitioner throughout the remainder of the proceedings below, effectively leaving no adequate remedy on appeal. Allstate Ins. Co.'. Langston, 655 So.2d 91, 94 (Fla. 1995); Barad & Co.'. EFTA00233732 McGuire, 670 So.2d 153 (Fla. 4th DCA 1996); see, Menke'. Broward School Bd, 916 So.2d 8

IRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs/Counterclaim Defendants, VS. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff. / DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ’S REDACTED MOTION TO MODIFY CONFIDENTIALITY ORDER Defenda

! JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS, and CASE NO. CACE 15-000072 PAUL G. CASSELL, Plaintiffs, V. ALAN DERSHOWITZ, Defendant. MOTION TO QUASH OR FOR PROTECTIVE ORDER REGARDING SUBPOENA SERVED ON NON-PARTY JANE DOE NO. 3 Non-party Jane Doe 3, by and through unde

to protect a non-party from discovery that would result in “annoyance, embarrassment, oppression or undue burden or expense...” Al/state Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 2003) (Florida Supreme Court overturning denial of protective order and holding that “[d]iscovery of certain kinds of inform