Epstein Secrets

GARVY,ROBERT GELICKMAN,DONALD COOPER,J P POHLMANN,BURT ROOSEVELT,WILLIAM

Y MCINTOSH,HENRY BOOMHOWER,R FIGUEROA,BARBARA GOLDSMITH,GERALD C BAKER,HO

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

equesting party can show need and the inability to obtain the substantial equivalent by other means without undue hardship. Vesta Fire Ins. Corp. v. Figueroa, 821 So.2d 1233, 1234 (Fla. 5th DCA 2002)(the showing of need and undue hardship necessary to overcome the work product immunity must include speci

r3-043?) Later that year, he attended classes at Cooper Union until he changed colleges in 1971.(34) From

react to if'. He alleged the meeting had taken place in London. W223 In a court filing, Andrew's lawyers had previously referred to a statement by Figueroa's sister, Crystal Figueroa, who alleged that in her bid to find victims for Epstein, Giuffre bad asked her, "Do you know any girls who are kind of s

3131-321 Later that year, he attended classes at Cooper Union until he changed colleges in 1971.131 From

w to react to it". He alleged the meeting had taken place in London.= In a court filing, Andrew's lawyers had previously referred to a statement by Figueroa's sister, Crystal Figueroa, who alleged that in her bid to find victims for Epstein, Giuffre had asked her, "Do you know any girls who are kind of s

s.faILI2 Later that year, he attended classes at Cooper Union until he changed colleges in 1971.E'1 From

eact to it". He alleged the meeting had taken place in London.P 1( -3 In a court filing, Andrew's lawyers had previously referred to a statement by Figueroa's sister, Crystal Figueroa, who alleged that in her bid to find victims for Epstein, Giuffre had asked her, "Do you bow any girls who are kind of sh

#86198- 759 16/5 11:35 AM 4 I/M Placed in SHU Cooper #92299-054, Ferrer #79793-054, Dockery #60685-05

Watch call in progress 6:15 PM 9N body alarm activation 6:22 PM 9n Body alarm cleared 6:23 PM 2 inmates escorted from unit IN to ZA for fighting: Figueroa 173822-053, Maquilon #76315-054 791 71/i 6:37 PM +3 Chan #86467-054, Reyes 61643-054, #85310-054, 794 70/5 6:49 PM -1 Time serve court release:

#86198- 759 76/5 11:35 AM 4 I/M Placed in SHU Cooper #92299-054, Ferrer #79793-054, Dockery #60685-05

Watch call in progress 6:15 PM 9N body alarm activation 6:22 PM 9n Body alarm cleared 6:23 PM 2 inmates escorted from unit IN to ZA for fighting: Figueroa #73822-053, Maquilon #76315-054 791 71/f 6:37 PM +3 Chan #86467-054, Reyes 61643-054, Williams #85310-054, 794 70/5 6:49 PM -1 Time serve court