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

ion of confidential information without conducting an in camera review to determine whether the assertion of privilege is valid. See Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2009). 8. If disclosure is made, this court should then determine what portions of th

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

on of confidential information without conducting an in camera review to determine whether the assertion of privilege is valid. See Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2009). 7. Moreover, the right to privacy encompasses at least two different kinds of

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

on of confidential information without conducting an in camera review to determine whether the assertion of privilege is valid. See Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2009). 6,7. Moreover, the right to privacy encompasses at least two different kinds o