Epstein Secrets

luding alleged victims), which would necessarily thwart such individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. &2e generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in ones sexual matters and is not limi

e theory of the requestor's case, or to some significant aspect of the case); Ashemimry v. Ba Nafa, 847 So.2d 603 (Fla. 5th DCA 2003). In addition, Florida Rule of Civil Procedure 1.280(b)(3), does allow discovery of fact work product where the requesting party can show need and the inability to obtain the substantia

, will take the video deposition of: NAME AJ DiScala DATE AND TIME PLACE Wednesday May 25, 2011 10:30 a.m. Dewey I,eBoeuf 1301 Avenue of the Americas New York, NY 10019 *The deponent has been instructed to bring with him all documents listed in Schedule A attached hereto. upon oral examination

CA040800XXXXMB AG RE-NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM TO: All Counsel of Record PLEASE TAKE NOTICE that the undersigned, pursuant to Florida Rule of Civil Procedure 1.310(b)(4), will take the video deposition of: NAME AJ DiScala DATE AND TIME PLACE Wednesday May 25, 2011 10:30 a.m. Dewey I,eBoe

itle 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 33. Specifically, Defendant Epstein: (a) knowin

the court reasoned that the purpose of discovery is to eliminate the likelihood of surprise and to Insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1)• see also Surf Drugs. Inc.. v. Vermette 236 So.2d 108, 111 (Fla. 7 EFTA00175217 Case 9:09-cv-80656-KAM Document 5 Entere