Epstein Secrets

FY that on September A 2010 a copy of the foregoing has been served via U.S. Mail and email transmittal to all those on the attached service list. Jack Scarola Searc Denne Scarol Barnhart & Shipley West Palm Beach, FL 33409 By: Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P

to all those on the attached service list. Jack Scarola Searc Denne Scarol Barnhart & Shipley West Palm

ction may not invoke the fifth amendment and refuse to comply with the defendant's discovery requests, thereby thwarting the defendant's defenses." Rollins Burdick Hunter of New York Inc. v. Euroclassic Limited, Inc., 502 So. 2d 959 (Fla. 3"I Dist. Court App. 1983). Here, Epstein is trying to do precisely what the "w

E-Mail: [email protected] Seamy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes B

ent. 994 So. 2d at 478. Moreover, "[a] civil litigant's fifth amendment right to avoid self-incrimination may be used as a shield but not a sword." Rollins Burdick Hunter of New York, Inc. v. Euroclassics Ltd., Inc., 502 So. 2d 959, 962 (Fla. 3d DCA 1987). Thus, "where the party claiming a Fifth Amendment privilege i

action may not invoke the fifth amendment and refuse to comply with the defendant’s discovery requests, thereby thwarting the defendant’s defenses.” Rollins Burdick Hunter of New York, Inc. v. Euroclassic Limited, Inc., 502 So. 2d 959 (Fla. 3d DCA 1983).. For the same reasons, Epstein should be precluded from advancing

I HEREBY CERTIFY that on November U , 2010 a copy of the foregoing has been served via Fax and U.S. Mail to all those on the attached service list. Jack Scarola Searcy, Denney, Scarola, Barnhart & Shipley 2139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 By: 42 HOUSE_OVERSIGHT_013360 --- PAGE BREAK -

ber U , 2010 a copy of the foregoing has been served via Fax and U.S. Mail to all those on the attached service list. Jack Scarola Searcy, Denney, Scarola, Barnhart & Shipley 2139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 By: 42 HOUSE_OVERSIGHT_013360 --- PAGE BREAK --- SERVICE LIST Christo