Epstein Secrets

6843 2: BANASIAK, JANUSZ J SR 742 EDGEBROOK LN 096-64-)000( (212) 751-1212 4/1953 BANASIAK. J WEST PALM BEACH. FL (561) 793-4471 BANASLAK, JANUSZ 33411-5301 (646) 476-6914 (646) 650-5100 358 EL BRILLO WAY PALM BEACH, FL 33480- 4730 6100 RED HOOK QTRS STE 8-3 ST THOMAS. VI 00802- 1348 5

gh "[s]ome older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipatio

a Belohlavic and ASA Daliah Weiss at the State Attorney's Office. I made telephone contact with ASA Weis package and request an interview with and Janusz Banasiak. She advised she would assist in attempting to EFTA00230988 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 68 Time: 8:47:53 Incident Report

racy claim against must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).10 10 This case is governed by the general rule. Cf. Churr

her Florida state and federal courts. See, SCI Funeral Svs. of Fla., Inc. v. Henry, 839 So. 2d 702, n.4 (Fla. 3d DCA 2002) (“As the Levin court cited Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA, 1984), with approval, presumably the cause of action for malicious prosecution continues to exist and

country and was back in France with no plans to return. This information was untrue; Brunel was actually staying with Epstein in West Palm Beach. See Banasiak deposition, deposition attachment #16 at 154-160 and 172-175; see also pages from Epstein's probation file evidenelne Jean Luc Brunel. (JLB) staying

son to believe that Sarah Kellen, Larry Visoski, Larry Harrison, David Rogers, Louella Rabuyo, Nadia Marcinkova, Ghislaine Maxwell, Mark Epstein, and Janusz Banasiak all had lawyers paid for by Epstein. Because Epstein and the co-conspirators in his child molestation criminal enterprise blocked normal discovery av