Epstein Secrets

, C.M.A., the information sought by the Defendant is protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee v. Redmond, 518 U.S. 1, 116 S.Ct. 1923 (1996)("AII agree that a psychotherapist privilege covers confidential communications made to licensed psychi

ht to relief above the speculative level, see 5 C. Wright & A. Miller, Federal Practice and Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller) ("[T]he pleading must contain something more ... than ... a statement of facts that merely creates a suspicion [of] a legally cognizable

350 444 West Railroad Avenue West Palm Beach FL 33401 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Bradley J. Edwards Farmer, Jaffee, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale FL 33401 Marc S. Nurik Law Offices of Marc S. Nurik O

he Court can determine whether Plaintiff "had a reasonable belief, based on facts and circumstances known to him, in the validity of his claim." See Wright v. Yurko, 446 So. 2d 1162, 1166 (Fla. 5th DCA 1984) (defining probable cause) (citing Goldstein v. Sabella, 88 So. 2d 910 (Fla. 1956)). Bifurcatin

rican Airlines had made "a • compelling argument for recognition of a limited common law privilege for the ASAP materials." Id. at 1533. Relying on Jaffee, Judge Marcus found that he had the ability "to recognize new privileges, consistent with Rule 501 of the Federal Rules of Evidence, in cases arisin

D.Me.2001) federal courts apply federal law when ad ressing the work product doctrine, even in di- versity cases lacking any federal ques- tion); 8 Wright, Miller & Marcus, Feder- al Practice and Procedure: Civil 2d. § 2023 (2d ed. 1994) ("At least since the adoption of Rule 26(13)(3) in 1970, it has

merican Airlines had made "a compelling argument for recognition of a limited common law privilege for the ASAP materials." Id. at 1533. Relying on Jaffee, Judge Marcus found that he had the ability "to recognize new privileges, consistent with Rule 501 of the Federal Rules of Evidence, in cases arisin

ted a `very lim- ited and seemingly judicious restriction,' 501 F.2d, at 151, nevertheless considered it versible *230 error. Citing United States Wright, 160 U.S.App.D.C. 57, 68, 489 .2d 1181, 1192 (1973), the court found that the Fifth Amendment prohibited the disclosure condition imposed in this