Epstein Secrets

regoing was sent by fax and U.S. Mail to the following addressees on this 11th day of February , 2009: Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Bamhart & Jack Alan Goldberger Phone Phone Fax Fax Co-Counsel for Defendant Jeffrey Epstein Counsel for Plaintiff P.A. EFTA0072270

urdensome and over- broad, but also constituted a fishing expedition un- related to the issues raised by the pleadings. In Allstate Insurance Co. v. Langston, 655 So.2d 91, 95 (Fla.1995), the supreme court held that certi- orari was available and should be used to quash an order "to the extent that it pe

asonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege. 23. The written fee agreement with Searcy Denney firm for their representation of you in this case. ANSWER: Objection. Edwards objects to the above-cited Requests to Produce on the purported gro

tted to discover relevant evidence that would be inadmissible at trial, if it may lead to the discovery of relevant evidence." Allstate Ins. Co. v. Langston, 655 So. 2d 91, 93 (Fla. 1995). As provided in detail below, Edwards's objections to 3 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL

ach, FL 33401-5012; Marc S. Nurik, Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, P.O. Drawer 3626, West Palm Beach, FL 33409. - 5 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POIN

ated to lead to the discovery of admissible evidence in the case in which the discovery is sought. Fla. R. Civ. P. 1.280(b)(1); Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). 10. "Pretrial discovery was implemented to simplify the issues in a case, to eliminate the element of surprise, t

asonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege. 23. The written fee agreement with Searcy Denney firm for their representation of you in this case. ANSWER: Objection. Edwards objects to the above-cited Requests to Produce on the purported gro

tted to discover relevant evidence that would be inadmissible at trial, if it may lead to the discovery of relevant evidence." Allstate Ins. Co. v. Langston, 655 So. 2d 91, 93 (Fla. 1995). As provided in detail below, Edwards's objections to 3 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL

asonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege. 23. The written fee agreement with Searcy Denney firm for their representation of you in this case. ANSWER: Objection. Edwards objects to the above-cited Requests to Produce on the purported gro

tted to discover relevant evidence that would be inadmissible at trial, if it may lead to the discovery of relevant evidence." Allstate Ins. Co. v. Langston, 655 So. 2d 91, 93 (Fla. 1995). As provided in detail below, Edwards's objections to 3 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL