judgment is proper as a matter of law. See Davis v. Hathaway, 408 So. 2d 688, 689 (Fla. 2d Dist. Ct. App. 1982); see also Holl, 191 So. 2d at 43. B. Epstein's Claims Regarding Edwards Have Absolutely No Factual Basis. 5 EFTA00725973 This is not a complicated case for granting summary judgment. To the co

A. Edwards Needs Epstein's Own Words to Defend Against Epstein's Civil Suit and to Pursue his Counterclaim for Compensatory and Punitive Damages 8 B. Epstein's Statements Are Not Available from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80

ated by the Court, that the depositions be needed "solely" as a result of a recent ruling, and the Motion should be denied on those grounds alone. B. Epstein's Prior Counsel Failed to Set L.M. and Jane Doe's Depositions, Despite Requesting and Receiving Dates for Their Depositions in August 2017. 7. The M

nkruptcy Court. That Motion is set for hearing for January 27, 2011. A Notice of Filing containing that Motion was filed with this Court [DE 1197]. B. Epstein's Attempts to Involve this Court in the State Litigation Despite that summary and protective order motions are pending in state court, Epstein contin