Epstein Secrets

iv. P. 53(e), and other applicable Federal Rules and Local Rules. In support, Epstein states: I. This court entered an order (DE 555) stating that Alfredo Rodriguez ("Rodriguez")(DE 469), must produce, to the extent in his possession, " ... any and all journal, notes, diaries, and writings relating to Jeffrey E

he extent in his possession, " ... any and all journal, notes, diaries, and writings relating to Jeffrey Epstein including the journal described by Rodriguez to Palm Beach Police that [allegedly] contains the names of girls who visited the residence." (DE 555, p.2) 2. As set forth m Rodriguez's depositi

hrough a free-standing action for injunctive relief or in conjunction with a tort action for, among other things, breach of fiduciary duty. See, M·, Saini v. International Game Technology, 434 F.Supp.2d 913, 924 (D.Nev. 2006)(court finds that company had shown likelihood of success in proving breach o

ctive Order pursuant to Fed.R.Civ.P. 26(c). In support, Epstein states: Procedural Background 1. This court entered an order (DE 555) stating that Alfredo Rodriguez ("Rodriguez")(DE 469), must produce, to the extent in his possession, " ... any and all journal, notes, diaries, and writings relating to Jeffrey E

ing to Jeffrey Epstein including the journal described by Case 9:08-cv-80119-KAM Document 560 Entered on FLSD Docket 06/10/2010 Page 2 of 11 Rodriguez to Palm Beach Police that [allegedly) contains the names of girls who visited the residence." (the "journal" or "book") (DE 555, p.2) 2. On June 4

hrough a free-standing action for injunctive relief or in conjunction with a tort action for, among other things, breach of fiduciary duty. See, M·, Saini v. International Game Technology, 434 F.Supp.2d 913, 924 (D.Nev. 2006)(court finds that company had shown likelihood of success in proving breach o

ctive Order pursuant to Fed.R.Civ.P. 26(c). In support, Epstein states: Procedural Background 1. This court entered an order (DE 555) stating that Alfredo Rodriguez ("Rodriguez")(DE 469), must produce, to the extent in his possession, "...any and all journal, notes, diaries, and writings relating to Jeffrey Eps

her third parties or attach any portion of same to any pleadings pending the outcome of the Rule 4 Appeal. att infra A roument 3. As set forth in Rodriguez's deposition, he was an employee of Epstein. Rodriguez Deposition, Exhibit "A" at p. 12-13. Moreover, as an individual employee, Rodriguez claims

ough a free-standing action for injunctive relief or in conjunction with a tort action for, among other things, breach of fiduciary duty. agg, a g., Saini v. International Game Technology, 434 F.Supp.2d 913, 924 (D.Nev. 2006)(court finds that company had shown likelihood of success in proving breach o

There are at least two potential avenues through which JE can seek to obtain return of the stolen book and/or a prohibition against dissemination by Rodriguez (leaving aside the procedural issues present at this stage of the proceedings, after the Magistrate Judge has already ordered Rodriguez to produce

ough a free-standing action for injunctive relief or in conjunction with a tort action for, among other things, breach of fiduciary duty. See, e.g., Saini v. International Game Technology, 434 F.Supp.2d 913, 924 (D.Nev. 2006)(court finds that company had shown likelihood of success in proving breach o