Epstein Secrets

25 of 37 Doe v. Epstein 08-CV80119 Page No. 25 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N

Fourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shalom/1 v. State 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free from

Fla. 2001); 16 Case 9:08-cv-80119-KAM Document 477 Entered on FLSD Docket 02/26/2010 Page 17 of 24 Doe v. Epstein 08-CV80119 Page No. 17 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the

Fourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, I 50-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free fr

S.D. Fla. 2001); Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 25 of 37 Doe v. Epstein 08-CV80119 Page No. 25 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the

Fourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free fro

testimony by the attorney performing the services and by an expert as to the value of those services." Pridgen v. Agoado, 901 So.2d 961, 962 quoting Cooper v. Cooper, 406 So.2d 1223, 1224 (Fla. 4I" DCA 1981). See also, Snow v. Harlan Bakeries, Inc., 932 So.2d 411 (Fla. 2nd DCA 2006). While there was a

relevant to the case. Without this information concerning the plaintiffs alleged status as a "holder in due course" of the note and mortgage (which the Florida Supreme Court apparently believes is relevant to any resolution of these foreclosure cases, thus #1 above), the defendant cannot ' Defendant had been pro se in t

Sec. Litig., 147 F.R.D. 208 (N.D. Cal. 1992)). See also Cooper Hosp./Univ. Med. Ctr. v. Sullivan, 183 F.R.D. 119, 131 (D.N.J. 1998) ("The fact that Cooper attempted to preserve the work-product privilege in its letter of transmittal and confidentiality agreement with the State does not alter this conc

n-discovery portions of the Federal Rules of Civil Procedure would be stripped of much of their meaning. . . . 329 U.S. 495 (1947). As later put by the Florida Supreme Court, when discussing the work-product doctrine: "A search for truth and justice can be accomplished only when all relevant facts are before the judicia

17 of 24 Doe v. Epstein 08-CV80119 Page No. 17 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N

Fourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free fro