Epstein Secrets

ENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 EDWARDS, et al., Plaintiffs / Counterclaim Defendants, v. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT / COUNTERCLAIM PLAINTIFF ALAN DERSHOWITZ'S MEMROANDUM IN OPPOSITION TO JANE DOE NO. 3'S MOTION TO

72 EDWARDS, et al., Plaintiffs / Counterclaim Defendants, v. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT / COUNTERCLAIM PLAINTIFF ALAN DERSHOWITZ'S MEMROANDUM IN OPPOSITION TO JANE DOE NO. 3'S MOTION TO OUASH OR FOR PROTECTIVE ORDER Defendant / Counterclaim Plaintiff Alan Dershowitz ("Dershowi

ena served on Jane Doe No. 3 is intended to accomplish precisely that goal. For example, the subpoena seeks "[a]ll documents that reference by name, Alan M. Dershowitz, which support and/or confirm the allegations set forth in" Jane Doe No. 3's declarations submitted in the Federal Action, as well as "[a]ny documen

im Plaintiff. DEFENDANT / COUNTERCLAIM PLAINTIFF ALAN DERSHOWITZ'S MEMROANDUM IN OPPOSITION TO JANE DO

determine whether the requesting party establishes a need for the information that outweighs the privacy rights of the non-party." Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 14 EFTA00582662 So.3d 620, 622 (Fla. 4th DCA 2009). Assuming that the testimony and information sought in the sub

im Plaintiff. DEFENDANT / COUNTERCLAIM PLAINTIFF ALAN DERSHOWITZ'S MEMROANDUM IN OPPOSITION TO JANE DO

ENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 EDWARDS, et al., Plaintiffs / Counterclaim Defendants, v. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT / COUNTERCLAIM PLAINTIFF ALAN DERSHOWITZ'S MEMROANDUM IN OPPOSITION TO JANE DOE NO. 3'S MOTION TO

ted pro hac vice) WILEY REIN LLP 1776 K Street NW Washington, DC 20006 20 EFTA00584081 Phone: (202) 719-7000 Fax: (202) 719-7049 Counsel for Alan M. Dershowitz 21 EFTA00584082 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E- mail on May 6, 2015,46,;

ena served on Jane Doe No. 3 is intended to accomplish precisely that goal. For example, the subpoena seeks "[a]ll documents that reference by name, Alan M. Dershowitz, which support and/or confirm the allegations set forth in" Jane Doe No. 3's declarations submitted in the Federal Action, as well as "[a]ny documen

determine whether the requesting party establishes a need for the information that outweighs the privacy rights of the non-party." Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So.3d 620, 622 (Fla. 4th DCA 2009). Assuming that the testimony and information sought in the subpoena is, in fact,

32, 08-80380, 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, M

on of confidential information without conducting an in camera review to determine whether the assertion of privilege is valid. See Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2009). 6,7. Moreover, the right to privacy encompasses at least two different kinds o