Epstein Secrets

Mr. Marc Nurik, One East Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301; Mr. Jack Scarola, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL; Mr. Gary Farmer, 425 N. Andrews Ave., Suite 2, Fort Lauderdale, FL 33301 and Mr. Jack Goldberger, 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-

stein, Palm Beach County Case #50200SCA028058XXXXMB), Jane Doe' (Jane Doe v. Jeffrey Epstein, United States District Court Case #08-civ-80893-Marra/Johnson), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not yet filed an action against Jeffrey Epstein, and any

, Williaria Berger, Michael Fisten, Ken Jenne, David Boden, Deborah Villegas, Andrew Barnett, Patrick Roberts, Richard Fandry, Christina Kittennan, Gary Farmer and Bradley Edwards, on the one hand, and any of the following regarding Jeffrey Epstein: 2 EFTA00208198 Case 9:08-cv-80736-KAM Document 177-1 E

by privilege, then a privilege log must be prepared and attached to the response, or the privilege is waived See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001) (stating that failure to provide a reason for privilege and prepare a privilege log constitutes waiver of the p

Plaintiff except for materials related to new or ongoing cases AND on the condition that they be produced "For Attorneys' Eyes Only. (Exhibit 3.) Gary Farmer, Jr. told the Special Master he would then only list on the new privilege log work product materials for existing cases and attorney-client privileg

found to be insufficient on its face and not-compliant with the requirements of Florida Rule of Civil Procedure 1.280(b)(5)7 and TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Edwards has claimed that none of the documents on the disc that were listed on his privilege log had ever been

February 24, 2011. Respectfully submitted, 4494X CV 711-42— k Joseph L. Ackerman, Jr. JLA/nat cc: Jack Scuola, Esquire (via email and U.S. Mail) Gary Farmer, Jr., Esquire (via email and U.S. Mail) Seth Lehrman, Esquire (via email and U.S. Mail) Miami • Fort Lauderdale • West Palm Beach EFTA00283060 F

5) of the Florida Rules of Civil Procedure as that Rule has been interpreted by the Fourth District Court of Appeal. 3. In TIG Insurance Corp. v. Johnson, 799 So. 2d 339 (Fla. 4'h DCA 2001), the court denied a writ of certiorari sought from an order requiring a party to produce documents because the

privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 14173 10/21/2009 Gary Farmer Bradley Edwards Stanely Arkin Work Productattorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admiss

radley Edwards RE:Epstein Joint W/P Priv. 11560-11562 10/02/2009 Bradley Edwards Katherine Jacquie FW:Meeting w/Stanley Arkin Joint W/P Priv. Johnson 11444-11448 09/28/2009 Bradley Edwards Amy Ederi FW:Epstein Depo Joint W/P Priv. 05823 09/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein