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

y, provides that every natural person has the right to be let alone and free from governmental intrusion into the person's private life. Colorado v. Bertine, 479 U.S. 367, 387 (1986); State v. Jardines, 9 So.3d I (Fla. 3d DCA 2008)(the Fourth Amendment clearly protects the right of people to be secure i

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

y, provides that every natural person has the right to be let alone and free from governmental intrusion into the person's private life. Colorado v. Bertine, 479 U.S. 367, 387 (1986); State v. Jardines, 9 So.3d 1 (Fla. 3d DCA 2008)(the Fourth Amendment clearly protects Case 9:08-cv-80119-KAM Documen

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

y, provides that every natural person has the right to be let alone and free from governmental intrusion into the person's private life. Colorado v. Bertine, 479 U.S. 367, 387 (1986); State v. Jardines, 9 So.3d 1 (Fla. 3d DCA 2008)(the Fourth Amendment clearly protects the right of people to be secure i