…1038. The confidentiality order also should, among other protections, preclude Plaintiffs from even referencing any of Dershowitz's specific personal financial information in any public court filing in this action. CONCLUSION 11. As shown above, the Plaintiffs have served "net…
…2000). The specific facts cited herein, which are independently verifiable from numerous independent sources, including multiple court filings, are indisputable, far exceed the minimal threshold, and establish as a matter of law that Epstein had legally sufficient probable cause to…
…asked the Court to enter: a Protective Confidentially Order which (1) limits the dissemination of certain Confidential Discovery Material ("CDM") described below, to a designated list of the Plaintiffs' counsel and support staff, and (2) prohibits any party from filing …
…22 transcripts of depositions or excerpts of depositions — the "Attachments," most of which were taken prior to the filing of this action in 2009 and before. The other "Exhibits" are a compendium of unworn letters, pleadings and other court filings…
…the attorneys listed on the Service List below on November 14, 2018, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1). LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 930 …
…1271 (11th Cir. 1983) ("in some circumstances, a lawyer's unprofessional conduct may vitiate the work product privilege.") As evidenced by the court filings attached', Epstein's counsel even before the hearing filed notice of "no-objection" to a temporary…
…that the foregoing document has been furnished to the attorneys listed on the Service List below on July 2018, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1). LINK & ROCKENBACH, PA …
…details. It is readily apparent that Edwards' sole purpose in placing such scurrilous "facts" and materials into the court file and the public domain is to vilify Epstein. There can be no other reason for Edwards' baseless filing. Moreover, the…
…foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF…
…foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF…
…foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF…
…foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF…
…foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF…
…term is inappropriate because it is “guaranteed” to generate “thousands of hits.” See, Supplement at 4. 3 With the exception court filings and discovery in this case (which the Plaintiff already has), the results would be all privileged documents. Plaintiff…
…foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF…
…foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF…
…litigation. Epstein makes no attempt to support the trial court's erroneous statement, but follows it with the statement that all of Epstein's filings "were done by an attorney in good standing with the Florida Bar" (AB pp. 14…
…at the outset, redacted the names of Edwards' three clients in the court filing despite Edwards' naming them on his witness list and filing a deposition transcript of one of them without protection of their anonymity. It was Epstein and…
…litigation. Epstein makes no attempt to support the trial court's erroneous statement, but follows it with the statement that all of Epstein's filings "were done by an attorney in good standing with the Florida Bar" (AB pp. 14…
…of depositions or excerpts of depositions — the "Attachments," most of which were taken prior to the filing of this action in 2009 and before. The other "Exhibits" are a compendium of linsworn letters, pleadings and other court filings, hearing transcripts…
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