Epstein Secrets

the issues and the defenses in the litigation"). W. The information simply falls under the "highly pr

s and the defenses in the litigation"). W. The information simply falls under the "highly protected category of opinion work-product." Id; see also Fla.R.Civ.Pro. 1.280. Also, Counsel for Jane Does 2-8 in the Federal companion cases apparently obtained a copy of the file retained by the Palm Beach State

a Raton, Florida 33431 by mail on April 8, 2010 W. Trent Steele 8902 SE Bridge Road Hobe Sound. FL

gment hearing, defendant objects to same since the note would need to be authenticated and no such document [sworn or certified copy as required by Fla.R.Civ.P. 1.510(e)] was filed in this case at least 20 days before the summary judgment hearing as required by Fla.R.Civ.P. 1.510(c). Plaintiff Has Never

other investigators. Therefore, it was clear that despite the fact that Mr. Edwards and Mr. Fisten discussed Epstein and the Jane Doe matters with George Rush of the NY Daily News regarding the Epstein matter, he would not be answering any questions regarding what Fisten specifically discussed with Mr. Ru

vidence that would be inadmissible at trial, so long as it is reasonably calculated to lead to the discovery of admissible evidence. Rule 1.280(b), Fla.R.Civ.P. (2008). Wherefore, Epstein requests that this court grant the relief requested herein, including, but not limited to, ordering that Edwards retu

other investigators. Therefore, it was clear that despite the fact that Mr. Edwards and Mr. Fisten discussed Epstein and the Jane Doe matters with George Rush of the NY Daily News regarding the Epstein matter, he would not be answering any questions regarding what Fisten specifically discussed with Mr. Ru

vidence that would be inadmissible at trial, so long as it is reasonably calculated to lead to the discovery of admissible evidence. Rule 1.280(b), Fla.R.Civ.P. (2008). Wherefore, Epstein requests that this court grant the relief requested herein, including, but not limited to, ordering that Edwards retu

., Exhibits "C" and "D", Affidavits of Richard C.W. Hall, outlining the psychological issues experien

n of litigation or for trial. ace Alachua General Hospital. Inc. v. Zimmer USA. Inc., 403 So.2d 1087 (Fla. 1st DCA 1981); Fed.R. Civ.Pro. 26(bX3XB); Fla.R.Civ.Pro. 1.280; In re Faro Technologies Securities Litigation, 2008 WL 205318 (M.D. Fla. 2008); Lake Shore Radiator. Inc. v. Radiator Express Warehouse