Epstein Secrets

JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER. MCNAMARA RUDA DAVID YAREMA I FIORJOA BOARD GUMMED CM!. TRW. LAWYER IAOMITIIID TO PRACTICE IN IRMO* AND COLORADO BURtvtAN, CRITTON LUTTIER&COLEMAN.LLY YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP December 9, 2009 BY HAND DELIVERY Judge Donald Ha

spection. See Johnson v. Mundy Industrial Contractors. Inc., 2002 WL 31464984 *3 (E.D .N.C. 2002) (quotations omitted). 42. As noted by professors Wright & Miller: [lit is clear that the right to discovery is a qualified right that does not extend to making unnecessary and unwarranted excursions onto t

ate different from any defendant." 28 U.S.C. § 1332(d)(2). Plaintiff here, a citizen of New Jersey, alleges against Defendants, citizens of Ohio or Colorado, an amount in controversy exceeding $5 million. (Compl. ¶¶ 20-23) Having confirmed jurisdiction, the Court now turns to the merits of Statebridge's

laintiff performed his own contractual duties. Pub. Serv. Enter. Grp., Inc. v. Philadelphia Elec. Ca, 722 F. Supp. 184, 219 (D.N.J. 1989) (citing 5 Wright & Miller, Federal Practice and Procedure, § 1235 at 189-90). In other words, "when pleading a claim for the breach of an express contract . . . the complain

rdale, Florida 33301 7 BY: BRADLEY EDWARDS, ESQ. 8 9 HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant 10 150 East 10th Avenue Denver, Colorado 80203 11 BY: JEFFREY PAGLIUCA, ESQ. 12 13 PODHURST ORSECK, P.A. Attorneys for Deponent 14 25 West Flagler Street Suite 800 15 Miami, Flor

m and foundation. 3 EFTA00595615 THE WITNESS: Yes. He wasn't always friendly See Menninger Decl., Ex. F, 10:6-14; 43:15-44:4 As explained in in Wright & Miller, Federal Practice and Procedures, the use of a document during testimony to refresh recollections is limited: The law also places limits on how cou