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Y MCINTOSH,HENRY BOOMHOWER,R FIGUEROA,BARBARA GOLDSMITH,GERALD C BAKER,HO
BEACH BEESON,JOHN KRAUSS,K W RINKER,JOHN J DERRIN,MICHELLE SALTZMAN,SHI
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
, 486 (1951). Epstein, in fact, can den; the occurrence of the assaults alleged and still maintain the safe harbor of the 5 Amendment.2 See Ohio v. Reiner, 532 U.S. 17(1991). 2 See DeLisi v. Bankers Ins. Company. 436 So.2d 1099 (Fla. 4th DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fift
for Jeff. The victim agreed and arrangements were made to.1 the victim to Epstein's house on a weekend. stated that she and (Later identified as Figueroa) picked up the victim at the victim's house. They traveled to E ns House and entered through the kitchen door. They met with the house chef and Eps
e unprotected assertions that anything in the computers is incriminating as a precondition to asserting the act-of-production privilege. See Ohio v. Reiner, 532 U.S. 17, 21 (2001)("[W]e have emphasized that one of the Fifth Amendment's basic functions . . . is to protect innocent men . . . who otherwis
Entities connected to both Figueroa and Reiner

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Bradley Edwards
PERSONJane Doe
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
George W. Bush
PERSON
Prince Andrew
PERSONMaria Farmer
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
Julie K. Brown
PERSON
Michael Jackson
PERSON
Kenneth Marra
PERSONMartin Weinberg
PERSONLeon Black
PERSONJoe Recarey
PERSON
George Mitchell
PERSON