Epstein Secrets

as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Pla

t marked as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Pla

is already in hand? Sic also Exhibits "D-1" and "D-2" and "E," a copy of the 89-page incident report marked as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Plaintiff claims was pulled from the residence at 358 Brillo Way. EFTA00317225 Case 9:08-cv-80119-KAM

Here, the standard is a showing of a need to obtain the information, and the inability to obtain the substantial equivalent without undue hardship. Metric Engineering, Inc. v. Small, 861 So. 2d 1248, 1250 (Fla. 1st DCA 2003)(To show `need,' a party must present testimony or evidence demonstrating the material requested

tepads). Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on March 19

certain notepads). Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on March 19

he substantial equivalent without undue hardship. Metric Engineering, Inc. v. Small, 861 So. 2d 1248, 1250 (Fla. 1st DCA 20

rt marked as an Exhibit by Plaintiffs counsel at Detective Recarey's deposition as well as certain message pads Pla

y in hand? See also Exhibits "D-1" and "D-2" and "E," a copy of the 89-page incident report marked as an Exhibit by Plaintiffs counsel at Detective Recarey's deposition as well as certain message pads Plaintiff claims was pulled from the residence at 358 Brillo Way. Case 9:08-cv-80119-KAM Document

Here, the standard is a showing of a need to obtain the information, and the inability to obtain the substantial equivalent without undue hardship. Metric Engineering, Inc. v. Small, 861 So. 2d 1248, 1250 (Fla. 1st DCA 2003)(To show 'need,' a party must present testimony or evidence demonstrating the material requested