Epstein Secrets

rth Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: [email protected] And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah' 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile:

822 E-mail: [email protected] And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

e general course of this proceeding. DE 330 at 23 (internal quotation omitted). 8 EFTA00210995 Donahay I. Palm Beach Tours & Transp., Inc,., 242 F.R.D. 685, 687 (S.D. Fla. 2007) (internal quotations omitted). The Federal Rules of Civil Procedure are broadly written and "strongly favor full discovery w

Sigrid S. McCawley Meridith Schultz Boors, SCHILLER & FLEXNER, LLP Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FiSTOS & LEHRMAN, P.L. Paul G. Cassell 383 S. University Street J. Stanley Pottinger SIM Is/ Nicole Simmons Nicole Simmons 10 EFTA00097405

intiff by her attorneys, Bradley Edwards and Paul Cassell. Menningcr DecL, Ex. A, p. 4. The very first lin

individuals may have discoverable information does not necessarily entitle a party to depose each such individual." Dixon v. Certainteed Corp., 164 F.R.D. 685, 692 (D.Kan.1996). "The factors relevant to determining whether a party should be entitled to more than ten depositions are now set forth in Fed.R.

Yes. Q: Would you have any reason to deny knowledge about that CD? MR. LINK: Object to the form. And I'm going to instruct him not to answer. MR. CASSELL: On what basis? MR. LINK: The question is not consistent with what Judge Ray, in his ruling, where he says very limited to asking him about his kno

October, 2018. I HEREBY CERTIFY that the undersigned attorney is appearing pro hac vice in this matter pursuant to court order dated May 4, 2018. Paul G. Cassell, Esq. S.J. Quinney College of Law at the University of Utah (above for address/contact purposes only, not to imply institutional endorsement) By

long as the information is reasonably calculated to lead to the discovery of admissible evidence." Donahay v. Palm Beach Tours & Transp., Inc„ 242 F.R.D. 685, 687 (S.D. Fla. 2007) (internal quotations omitted). The burden is on the party asserting a privilege or other basis for refusing to answer a depos