Epstein Secrets

by Sgt. , Officer and the Director of Security Allen MCEniry, per the request of Residential Life (Er

tment Record Custodian (collectively 'Town of Palm Beach Police Officers"), hereby move to quash the subpoena or for a protective order pursuant to Florida Rule of Civil Procedure 1.280(c) directing that discovery sought by the civil subpoenas for deposition issued by Plaintiff, B.B , and the cross-notices with subp

ility, value or damages of Edwards' claim in this action, would be a departure from the essential requirements of law and reversible on appeal. See Allen, supra; Woodward, supra. Therefore, Epstein requests that this Court enter an order protecting Any Other Tort Claimants and Epstein (the only parti

VE ORDER AND IN LIMINE OF UNRELATED SETTLEMENTS Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), moves for a protective order pursuant to Florida Rule of Civil Procedure 1.280(c) on the production and disclosure of any additional confidential settlement agreements and amounts and moves in limine pursuant to

them when it is possible to do so." Spiegel v. H. Allen Holmes, Inc., 834 So. 2d 295, 297 (Fla. 4th DCA

z, 785 So. 2d 589, 591 (Fla. 5th DCA 2001) ("[M]erely attaching an unswom document ... does not . . . satisfy the procedural strictures inherent in Florida Rule of Civil Procedure 1.510(e)."). Scarola and Edwards are veteran trial attorneys, are well aware of these Rules, and are more than familiar with the signific