Epstein Secrets

No. 2 v. Epstein Page 14 Request No. 14. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Haley Robson, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting

communications between Jeffrey Epstein and Haley Robson, including, but not limited to, letters, notes,

Citing to U.S. v. Lot 5. Fox Grove, supra, the Southern District Court, Florida, in Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006), stated — The Eleventh Circuit has also created a test for these circumstances. stating that where there exists a concurrent civil and criminal proceeding, a court must stay a ci

6/06/2017 Page 26 of 32 unfairly prejudice the opposing party. Tampa Bay Water v. HDR Engineering. Inc. 731 F.3d 1171, 1182 (11th Cir. 2013) citing Robinson v. Tyson Foods. Inc., 595 F.3d 1269, 1273 (11th Cir. 2010). In their state court tort actions against Epstein, both petitioners invoked the provisi

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire v. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet

/02/2017 Page 27 of 33 unfairly prejudice the opposing party. Tampa Bay Water v. HDR Engineering. Inc. 731 F.3d 1171, 1182 (11th Cir. 2013) citing Robinson v. Tyson Foods. Inc., 595 F.3d 1269, 1273 (11th Cir. 2010). In their state court tort actions against Epstein, both petitioners invoked the provisi

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire v. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet