Epstein Secrets

came and found the old car in the driveway? 19 20 A. Exactly, yes, with the police, yes. 20 21 Q. How did you remember that it was Tony 21 22 Figueroa? 22 23 A. It's the only person, male that I 23 24 remember. 24 25 Q. But you don't know his name? 25 Page 445 alrie, I guess. was to help

you're not required to 3 assume because some lawyers ask you a leading 4 question or suggested in a report or like the 5 police report like Mr. Mermelstein and Mr. Edwards 6 did, that did you tell the police officers X, Y, 7 or Z without showing you the statement. You're 8 not required to guess, I

Q. And when we were here, I think it was 11 last week or the last ten days anyway -- I could 12 tell you. On July 29th of this year, and Mr. 13 Mermelstein started with your deposition and then 14 others asked questions, when Mr. Mermelstein and I 15 think Mr. Edwards asked questions about did you 16

without undue hardship. Vesta Fire Ins. Corp. v. Figueroa, 821 So.2d 1233, 1234 (Fla. 5th DCA 2002)(the sh

tion of his Fifth Amendment rights. In fact, the Mermelstein and Horowitz firm was quoted in the Palm Beach P

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

heir civil case, but to gain information to aid in the future prosecution of Epstein in direct violation of his Fifth Amendment rights. In fact, the Mermelstein and Horowitz firm was quoted in the Palm Beach Post stating, among other things, that the book sold to undercover agents could open the door to fut

en 19 you came and found the old car in the driveway? 20 A. Exactly, yes, with the police, yes. 21 Q. How did you remember that it was Tony 22 Figueroa? 23 A. It's the only person, male that I 24 remember. 25 Q. But you don't know his name? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

Q. And when we were here, I think it was 11 last week or the last ten days anyway -- I could 12 tell you. On July 29th of this year, and Mr. 13 Mermelstein started with your deposition and then 14 others asked questions, when Mr. Mermelsteln and I 15 think Mr. Edwards asked questions about did you 16