Epstein Secrets

tricken as set forth hereinabove, and that the Court grant such other and further relief as deemed necessary and proper. Respectfully submitted, s/Christopher E. Knight Lilly Ann Sanchez Fla. Bar No. 195677 Christopher E. Knight Fla. Bar No. 607363 Helaine S. Goodner Fla. Bar No. 462111 FOWLER WHITE BURNETT P.

proof of service from Mr. Marsigliano attesting that he left M.J.'s complaint with the caretaker at Epstein's residence or usual place of abode." (D.E. 15 at p. II). This assertion is false. Defendant has never admitted that the proof of service states that Mr. Marsigliano left the Summons and Com

copy of her complaint and other documents with someone at the home", which is all that Plaintiff alleges, or whether Mr. Epstein had actual notice (D.E. 15 at 12), but, rather, whether the suit papers were left with "someone of suitable age and discretion who resides" at 9 East 71s' Street, New York.

ckerman, Jr. Florida Bar No. FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Easier Drive West Palm B Telephone: Facsimile: and Christopher E. Knight Florida Bar. No. FOWLER WHITE BURNETT, P.A. Espirito Santo Plaza, 14th floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: Facsimile:

asked solely to poison the wel1.6 The Court recently sustained Plaintiffs objections to discovery requests geared solely to alleged sexual activity (D.E. 148, 149, and 150). Accordingly, the sword and shield doctrine does not apply to the illegitimate and irrelevant questions which Plaintiff declined

ective order is not intended to nor does it apply to any person or party not explicitly named herein. Submitted by: Lilly Ann Sanchez, FBN 195677 Christopher E. Knight, FBN 607363 Joseph L. Ackerman, Jr., FBN 235954 Rodney J. Janis, FBN 647896 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler

18, 2010 oral ruling granting Trustee's Motion for Expedited Relief Seeking a Protective Order and Approving Proposed Document Production Protocol ( D.E. #617), hereby agree to and request Court approval of the following stipulation: It is expected that, to facilitate the sharing of RRA's information