7
Shared Docs
7
Same-Page
7 / 10
Mentions
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
ads). Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on March 19, 2010, the following exchange occurred: Mr. Kuvin: Okay. And what were the dates of the surveillance? Witness: [Referencing his Report] It appears she met with members of the B.S.F. unit, Burglary
t of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private
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
ic as eager and willing to cooperate" .= spencer Kuvin, who represented nine of Epstein's victims, said
ached by Andrew for an interview and labeled his statements as a way "to falsely portray himself to the public as eager and willing to cooperate" .= spencer Kuvin, who represented nine of Epstein's victims, said Andrew could be arrested if he ever returns to the United Statcs, saying "It is highly unlikely an
to react to it". He alleged the meeting had taken place in London.UJ 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
th committing a bregekofilma.= Andrew wore military uniform for a 15-minute vigil by the Queen's coffin at Westminster Hall on 16 September.= Lawyer Spencer Kuvin, who represented nine of Epstein's victims, was critical of Andrew's public role in the lead-up to the funeral and stated that "he is attempting no
Westminster Hall on 16 September.= Lawyer Spencer Kuvin, who represented nine of Epstein's victims, was
without undue hardship. Vesta Fire Ins. Corp. v. Figueroa, 821 So.2d 1233, 1234 (Fla. 5th DCA 2002)(the sh
ch 19, 2010, the following exchange occmTed: Mr. Kuvin: Okay. And what were the dates of the surveillanc
Y MCINTOSH,HENRY BOOMHOWER,R FIGUEROA,BARBARA GOLDSMITH,GERALD C BAKER,HO
MCDONALD,JOHN R BREKUS,GORDON L KUVIN,SANFORD F HARRINGTON,RICHARD L VILL
e possible last known addresses To Palm Beach County; obtained the recent booking page re: Preston Vinyard at PBSO records; checked for any recent Figueroa reports: checked and canvassed the neighbors near Vinyard's Ik/a, 2521 25th Lane: checked and in uired with tenant Shelly Manning at Anthony Figue
rent tenant and spoke with 2 neigh ors re: igueroa; c ecked at possible family, Charles Figueroa. Plantation; nobody home Checked Florida Bar re: Kuvin; checked federal civil, criminal and bankruptcy records re: Kuvin for personal and professional; obtained lilst of all federal case files that he w
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
torney for Jane Doe 101 and 102. 17 18 LEOPOLD-KUVIN 19 BY: ADAM 3. LANGIRD, ESQ. 2925 PGA Boulevar
Entities connected to both Figueroa and Spencer Kuvin

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSONJack Scarola
PERSONScott Rothstein
PERSON
George W. Bush
PERSONRobert D. Critton
PERSONMichael J. Pike
PERSONRobert C. Josefsberg
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONKatherine W. Ezell
PERSONRichard Horace Willits
PERSON
Sarah Kellen
PERSONIsidro Manuel Garcia
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Lake Worth
LOCATIONMermelstein & Horowitz
ORGANIZATION