Epstein Secrets

and communicative, courts have invoked the “required records” exception to the act of production doctrine. See Federal Saving & Loan Ins. Corp. v. Rodrigues, 717 F. Supp. 1424, 1427 (N.D. Cal 1988) (“required records” exception is a Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010

m of money which, according to his financial ability, will hurt, but not 3 Defendant’s reliance on Gallina v. Commerce and Industry Ins., 2008 WL 3895918 (M.D. Fla. 2008) is misplaced. Gallina is an insurance bad faith case and does not involve a claim o

ctrine. See Federal Saving & Loan Ins. Corp. v. Rodrigues, 717 F. Supp. 1424, 1427 (N.D. Cal 1988) (“requir

3 Defendant’s reliance on Gallina v. Commerce and Industry Ins., 2008 WL 3895918 (M

(4) the emotional distress was severe." Gallogly Rodriguez, 970 So. 2d 470, 471 (Fla. 2d DCA 2007) (citing L

iolation of Chapter 800 of the Florida Statutes." (DE 1-3 at 105.) Thus, the plaintiff has failed to allege a cause of action against See Baischl. Gallina, 346 F.3d 366, 373 (2d Cir. 2003) ("[A] plaintiff does not have standing if [sjhe suffered an injury that was indirectly (and hence not proximately