Epstein Secrets

CLUSION Based on the foregoing, Edwards' Renewed Motion for Summary Judgment should be denied. Dated: February 16, 2012. Respectfully submitted, Joseph L. Ackerman, Jr. Florida Bar No. FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Easier Drive West Palm B Telephone: Facsimile: and Christo

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

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 Drive West Palm Beach, Florida

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

V-80893-MARRABOHNSON Epstein's Reply to Edwards' Resp to Epstein's MPO and Objs of Certain Docs Paul G. Cassell, Esq. Respectfully submitted, /s/ Joseph L. Ackerman. Jr. Joseph L. Ackerman, Jr. Co-Counsel for Defendant Jeffrey Epstein pal WA80743\08-50893\Epsteins Reply to EA./ Rey to la's MPO and Obj to Discl

note from a review of the docket sheet in Doe v. U.S., that Judge Marra administratively closed the cases for non-prosecution on September 9, 2010 [D.E. 39]. Please recall the undersigned pointed out in Epstein's initial motion that this case has been languishing in excess -6- FOWLER WHITE BURNETT.