Epstein Secrets

rman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 954-524-2820 954-524-2822 - fax [email protected] Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, P.A. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 Jack Alan Goldberger, Esq. Atterbury Goldberger & Wei

sponse to Request for Admissions No. 11 was anything other than an admission, please explain why you did not admit that the history you gave to Dr. Ryan Hall at your Compulsory Medical Examination on February 5, 2010 ("CME") was completely true and accurate and describe any false or inaccurate statements

ead to the discovery of the admissible evidence; protected by privacy rights 05440-05441 04/01/2009 Bradley Edwards Carolyn (Legal Asst. to Jay Howell, Co- Counsel) CW Personal information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the disco

asonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05927 09/18/2009 Bradley Edwards Amy Swan Ryan Hall Psychiatrist Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide

ead to the discovery of the admissible evidence; protected by privacy rights 05440-05441 04/01/2009 Bradley Edwards Carolyn (Legal Asst. to Jay Howell, Co- Counsel) CW Personal information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the disco

asonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05927 09/18/2009 Bradley Edwards Amy Swan Ryan Hall Psychiatrist Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide